Suchergebnisse

The significant contribution of R&D to economic development and sustainability has been shown by various studies. Therefore, governments offer different fiscal instruments to attract R&D, especially regarding multinational entities (MNEs). One of the fiscal instruments are tax incentives for R&D. Furthermore, the EU has been working on the switch from Separate Taxation (ST) to Common Consolidated Corporate Tax Base (CCCTB) for longer than a decade, which will lead to harmonized R&D tax allowances, however without harmonizing the tax rates. Hence, this study aims at analyzing how ST and CCCTB impact the location of MNEs' R&D activities, tax burden and countries' tax revenue through a case study. The results show that, under ST, tax jurisdictions can stimulate MNEs' R&D activities by means of attractive tax allowances and lower tax rates. Especially for high-tax countries, the tax allowances represent an important tool for attracting R&D activities. However, under CCCTB, the location of R&D activities additionally depends on the Formula Apportionment (FA) factors of the tax base, where the countries cannot exert a direct influence. Hence, the reduction of tax rates remains the only tool left to Member States, which can lead to revenue loss on the whole. Furthermore, the FA of the tax base under CCCTB mitigates the impact of any dislocation of R&D to a low-tax country, which, under ST, leads to larger tax savings of MNEs and its impact on jurisdictions' tax revenue is greater.

AbstractMultinational enterprises (MNEs) are often accused of taking advantage of lax environmental regulations in developing countries. However, no quantitative analysis of the impact of doing business in nations of different income levels on environmental corporate social responsibility (ECSR) has been done prior to this study. Incorporating institutional factors in our approach, we argue that endoisomorphic and exoisomorphic pressures relating to ECSR impact MNEs differently according to the MNEs' level of activity in low‐, lower‐middle‐, upper‐middle‐, and high‐income nations. We predict and, using data from 113 companies, find that selling in poorer nations is positively associated with increased levels of ECSR. Our research suggests that MNEs may not be participating in a "race to the bottom" but may instead be responding to global institutional pressure by exceeding local norms for environmental stewardship. Alternative interpretations of our findings are discussed.

International human rights law (IHRL) has traditionally only imposed duties on states. But as multinational corporations (MNCs) and other business entities are perceived as increasingly powerful agents in the global economy, and capable of impacting on many of the interests protected by IHRL, scholars as well as practitioners argue that IHRL should be extended to apply to these entities. My argument in this thesis is twofold. Firstly, I make the normative case that calls for business accountability under IHRL misunderstand the particular role of IHRL, taking the point of IHRL as protecting important human interests against anyone who has the capacity to harm these interests. I argue that the role of IHRL is better understood as holding states accountable for the performance of their special institutional duties. If we were to extend international human rights duties to business entities, many of the core principles of IHRL would need to be changed which in turn would undermine the very identity of this body of law – it would no longer fulfil the distinct function of regulating political authority. I argue that it would impoverish our legal vocabulary if we were no longer able to express the distinction between state violations of human rights and harm done by private actors. And secondly, I argue that there are a number of practical challenges to extending IHRL to business entities, and that the implementation mechanisms of IHRL are currently not well-suited to address many of the concerns that give rise to calls for business-human rights-accountability in the first place. I conclude that an extension of IHRL may therefore not be the straightforward and effective solution that it tends to be made out in the current debate and that alternative approaches to business regulation may be preferable.

Corporate patents are perceived to be the key profit-drivers in many multinational enterprises (MNEs). Moreover, as the transfer pricing process for royalty payments is often highly intransparent, they also constitute a major source of profit shifting opportunities between multinational entities. For both reasons, MNEs have an incentive to locate their patents at affiliates with a relatively small corporate tax rate. Our paper empirically tests for this relationship by exploiting a unique dataset which links information on patent applications to micro panel data for European MNEs. Our results suggest that the corporate tax rate (differential to other group members) indeed exerts a negative effect on the number of patents filed by a subsidiary. The effect is quantitatively large and robust against controlling for affiliate size. The findings prevail if we additionally account for royalty withholding taxes. Moreover, binding 'Controlled Foreign Company' rules tend to decrease the number of patent applications.

With the development of technologies, space activities are becoming more diverse. There are many commercially profitable types of activities in which many legal entities from different countries take part. Given the high cost of space activities, a considerable number of multinational corporations with significant funds and capable of purchasing the most advanced technologies participate in it. Meanwhile, International Space Law was formed from the very beginning as an interstate one. Will the activities of legal entities, including multinational corporations, be regulated by International Law? The authors believe that there is no general rule, the position of legal entities is regulated by state agreements in each specific case.

Intro -- TAXING U.S. MULTINATIONAL CORPORATIONS POLICY OPTIONS AND CONSIDERATIONS -- TAXING U.S. MULTINATIONAL CORPORATIONS POLICY OPTIONS AND CONSIDERATIONS -- CONTENTS -- PREFACE -- Chapter 1 OPTIONS FOR TAXING U.S. MULTINATIONAL CORPORATIONS* -- SUMMARY -- Current Federal Tax Treatment of U.S. Multinational Corporations -- Policy Options -- A Worldwide System -- A Territorial System -- Other Options -- TWO BASIC APPROACHES TO TAXING MULTINATIONAL CORPORATIONS -- FEDERAL TAX TREATMENT OF U.S. MULTINATIONAL CORPORATIONS -- The Federal Corporate Income Tax -- U.S. Rules for Taxation of Income Earned Abroad -- Limits on Foreign Tax Credits -- Deferral of Taxes on Foreign Income -- Using Excess Credits to Shelter Income Repatriated from Low-Tax Countries -- Combining Deferral and Excess Credits -- Deductions for Expenses -- Limits on Deferral -- Impact of Foreign Tax Credits and Deferrals on Federal Revenues -- EFFECTS OF THE FEDERAL TAX TREATMENT OF U.S. MULTINATIONAL CORPORATIONS -- Location of Investment -- Profit Shifting -- Differing Treatment of Entities and Income -- Transfer Pricing -- Estimates of Profit Shifting -- Budgetary Effects of Decisions About Location and Profit Shifting -- POLICY OPTIONS -- Move More Toward a Worldwide Approach -- Eliminate Deferral -- Eliminate Deferral for Certain Countries -- Eliminate Deferral Related to Goods Produced Abroad -- Move Toward a Territorial Approach -- Exempt Active Dividends Earned Abroad from U.S. Taxation -- Apportion U.S. and Foreign Income by Formula -- Other Options -- Restructure the Foreign Tax Credit -- Treat Entities and Income Consistently -- Eliminate Check-the-Box Rules -- Defer Interest Deductions Related to Deferred Income -- APPENDIX: CORPORATE TAX RATES -- Statutory Corporate Income Tax Rates -- Average Tax Rates -- Effective Marginal Tax Rates -- End Notes

For many small and medium enterprises (SMEs), access to financing is a challenge. The World Bank Group estimates the finance gap among formal micro, small, and medium enterprises (MSMEs) in developing economies to be eighteen percent of GDP. This finance gap is of particular concern because SMEs are a leading driver of trade, economic development, and employment. Development finance institutions can play an active role by fostering initiatives, such as supply chain finance (SCF), that can for instance, drive local economic growth, increase financial inclusion, and support the closing of market gaps. This guidebook deals with development banks on a national and multinational level. Similarly, some of the discussed goals and roles can also apply to central banks, government agencies, or other public entities.

It is common to discuss multinationals as though they constitute a unified, single entity. This chapter unpacks that conception in two ways. Firstly it shows that multinationals have become very complex organizational entities. The nature of their internationalization varies greatly in terms of the location of their assets, their people, their supply chains and their sources of funding. The impact of financialization and the drive to minimize tax liabilities by taking advantage of tax havens and legal arbitrage has created a shadow reality based on shell offices, opaque trust funds and special purpose financial vehicles which are connected to the MNC in various ways. Secondly the chapter shows that this complexity leads to the formation of different interest groups within the MNC, especially between those actors embedded in the corporate headquarters and those in local subsidiaries. The ability of local actors to resist, adapt or conform to HQ demands drawing on a range of political and institutional resources is explored in the chapter.