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Annet Wanyana Oguttu - One of the best experts on this subject based on the ideXlab platform.
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resolving the conflict between controlled Foreign Company legislation and tax treaties a south african perspective
Comparative and International Law Journal of Southern Africa, 2009Co-Authors: Annet Wanyana OguttuAbstract:In order to prevent the avoidance of taxes that result from investing in offshore companies, countries often enact "Controlled Foreign Company" (CFC) legislation which ensures that the undistributed income of a controlled Foreign Company is not deferred, but it is taxed to its domestic shareholders on a current basis. However, the application of CFC legislation has been questioned on the basis that it contradicts some of the basic principles of double taxation treaties. In this article the salient aspects of tax treaties that are considered to be incompatible with CFC legislation are discussed. The article also analyses how the conflict between the conflict South Africa's South Africa's CFC legislation and its tax treaties can be resolved.
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the challenges that e commerce poses to international tax laws controlled Foreign Company legislation from a south african perspective part 2
SA Mercantile Law Journal = SA Tydskrif vir Handelsreg, 2008Co-Authors: Annet Wanyana OguttuAbstract:In terms of s 9D(12) of the Income Tax Act, a South African shareholder who together with connected persons holds 10 per cent to 25 per cent of the participation rights or voting rights in a CFC can elect to treat all his pro rata share of CFC income as taxable under s 9D even if he would have been granted an exemption under s 9D(9). Section 9D(13) provides that any resident who, together with connected persons, holds 10 per cent up to 25 per cent of the participation rights or voting rights of a Foreign Company may elect that this Foreign Company be deemed to be a CFC in relation to him for any of its Foreign tax years.
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the challenges that e commerce poses to international tax laws controlled Foreign Company legislation from a south african perspective part 1
SA Mercantile Law Journal = SA Tydskrif vir Handelsreg, 2008Co-Authors: Annet Wanyana OguttuAbstract:Faced with high rates of tax in their countries of residence, taxpayers involved in international trade are increasingly developing global tax avoidance strategies, in order to maximise profits. For most businesses, the possibility of reducing tax costs by basing a business offshore in a low tax jurisdiction is an inherent aspect of international tax planning. Where a Company is based in an offshore jurisdiction, it is not subject to domestic tax until its income is distributed to the shareholders as dividends.
Georg Wamser - One of the best experts on this subject based on the ideXlab platform.
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do us firms pay less tax than their european peers on firm characteristics profit shifting opportunities and tax legislation as determinants of tax differentials
2018Co-Authors: Michael Overesch, Sabine Schenkelberg, Georg WamserAbstract:Using pairs of similar US and European firms listed on the S&P500 or StoxxEurope600, we examine effective tax differentials between US multinational corporations (MNCs) and their European peers. We show that statutory tax rates and profit shifting opportunities are important determinants of effective tax rates. Our findings suggest substantially lower total tax payments of US MNCs after the 2017 US tax reform. Based on past reforms of Controlled Foreign Company (CFC) rules and of the principle of worldwide taxation, we confirm that international tax legislation affects effective tax expenses. We also provide evidence for heterogeneity in firm responses: MNCs with profit shifting opportunities benefit most from more-lenient CFC rules.
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the impact of controlled Foreign Company legislation on real investments abroad a multi dimensional regression discontinuity design
Journal of Public Economics, 2015Co-Authors: Peter Egger, Georg WamserAbstract:Controlled Foreign Company (CFC) rules are frequently imposed by countries as part of their anti-tax-avoidance legislation. This paper aims at quantifying the impact of the German CFC rule on the universe of Foreign investments held by German multinational firms. The German CFC legislation gives rise to a multi-dimensional regression discontinuity design, which allows us to estimate local average treatment effects along the dimensions determining treatment. Our results suggest a significant and economically large impact of the CFC legislation on multinationals' real activity abroad. We also find evidence of some heterogeneity in estimated treatment effects according to parametric as well as nonparametric estimates.
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the impact of controlled Foreign Company legislation on real investments abroad a two dimensional regression discontinuity design
2011Co-Authors: Peter Egger, Georg WamserAbstract:Controlled Foreign Company (CFC) rules are frequently imposed by countries as part of their anti-tax-avoidance legislation. This paper aims at quantifying their impact on Foreign investments by utilizing a regression discontinuity design and the universe of German Foreign investments notified to Deutsche Bundesbank. While most regression discontinuity designs are one-dimensional, German CFC legislation gives rise to a two-dimensional design. The latter allows the local average treatment effect (LATE) to be heterogeneous along the two treatment thresholds, which are related to the level of the Foreign corporate profit tax rate and to the returns on passive assets relative to total returns. We find clear evidence of a negative average LATE of the CFC legislation on the fixed assets held by German multinationals abroad. We find also evidence of some heterogeneity of LATE according to parametric as well as nonparametric estimates. On average, Foreign assets are estimated to respond by about 10 million Euros in the neighborhood of the intersection of both treatment thresholds. This evidence points to a significant and economically large impact of anti-tax-avoidance legislation on multinational firms’ real activity abroad.
Eric W K Tsang - One of the best experts on this subject based on the ideXlab platform.
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choice of international technology transfer mode a resource based view
Management International Review, 1997Co-Authors: Eric W K TsangAbstract:If a firm wants to transfer its technology to a Foreign country, which mode of transfer will it adopt? Voluminous studies have been conducted on the choice of Foreign market entry mode (e.g. Erramilli/Rao 1993, Goodnow/Hansz 1972, Woodcock/Beamish/Makino 1994). Several models of entry mode choice have been constructed for explaining entry behavior (Agarwal/Ramaswami 1992, Anderson/Gatignon 1986, Hill/Hwang/Kim 1990). Many of these studies are biased towards the marketing discipline with emphasis on product and market analysis. Technology transfer is often part of a Foreign market entry deal. However, if the major strategic intent of a firm is to transfer its technology across borders, it is doubtful how far the models of market entry are relevant. For example, acquisition of a local Company in a Foreign country is a rather commonly used strategy of entering into the Foreign market, but it is rarely an option for technology transfer. On the contrary, buying a Foreign Company may be motivated by technology acquisition. According to the Uppsala internationalization model, there are four successive stages of entering a Foreign market with increasing resource commitments - irregular export activities, export via independent agents, establishment of an overseas sales subsidiary and overseas production units (Johanson/Wiedersheim-Paul 1975). If a firm intends to transfer a cutting edge technology overseas, as discussed later in the article, it has little choice but uses a transfer mode that demands heavy resource commitments. Thus the model is not applicable in this case. In short, despite some overlaps, the factors influencing international technology transfer are more specific and quite different from those determining Foreign market entry. A separate treatment is therefore required. Technology transfer is an important research area. Conceptual models have been developed for examining influences on the effectiveness of technology transfer across nations (Kedia/Bhagat 1988, Tung 1994). Godkin (1988) produces a long list of factors which foster or hinder technology transfer. Tsang (1994) builds up a normative framework for recommending strategies for transferring technology to China. Rather surprisingly, little has been done on constructing a positive model for explaining the selection of technology transfer mode by the transferor. This article is an attempt to fill this literature gap. By using the resource-based perspective, rather than the well established transaction cost approach, it is hoped that the analysis would yield fresh insights. Much of the existing resource-based literature focuses on discussing the sustainability of a firm's competitive advantage (e.g. Amit/Schoemaker 1993, Grant 1991, Peteraf 1993, Reed/DeFillippi 1990). This article shows that the resource-based theory is equally applicable to analyzing a firm's other strategic concerns. The next section examines the nature of technology treating it as one form of firm resources. The resource commitments of different modes of international technology transfer are then discussed. Next, taking into account the major factors influencing the choice of transfer mode, a unified model is constructed. The model is dynamic in the sense that experience learned from a transfer mode has feedback effects on the firm's resources and affects its future transfer mode choice. At the same time, theoretical propositions are formulated in the model. Finally, a few concluding remarks are drawn. Technology as Firm Resources Penrose's (1959) seminal work was published a few decades ago, but only recently have researchers begun to focus on the exploitation of firm-specific resources as the foundation for formulating strategy. Broadly speaking, a firm's resources consist of all its assets, knowledge, employees, information systems, organizational structure, rules, procedures and so forth that are controlled by the firm. There are a number of ways of classifying firm resources. …
Peter Egger - One of the best experts on this subject based on the ideXlab platform.
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the impact of controlled Foreign Company legislation on real investments abroad a multi dimensional regression discontinuity design
Journal of Public Economics, 2015Co-Authors: Peter Egger, Georg WamserAbstract:Controlled Foreign Company (CFC) rules are frequently imposed by countries as part of their anti-tax-avoidance legislation. This paper aims at quantifying the impact of the German CFC rule on the universe of Foreign investments held by German multinational firms. The German CFC legislation gives rise to a multi-dimensional regression discontinuity design, which allows us to estimate local average treatment effects along the dimensions determining treatment. Our results suggest a significant and economically large impact of the CFC legislation on multinationals' real activity abroad. We also find evidence of some heterogeneity in estimated treatment effects according to parametric as well as nonparametric estimates.
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the impact of controlled Foreign Company legislation on real investments abroad a two dimensional regression discontinuity design
2011Co-Authors: Peter Egger, Georg WamserAbstract:Controlled Foreign Company (CFC) rules are frequently imposed by countries as part of their anti-tax-avoidance legislation. This paper aims at quantifying their impact on Foreign investments by utilizing a regression discontinuity design and the universe of German Foreign investments notified to Deutsche Bundesbank. While most regression discontinuity designs are one-dimensional, German CFC legislation gives rise to a two-dimensional design. The latter allows the local average treatment effect (LATE) to be heterogeneous along the two treatment thresholds, which are related to the level of the Foreign corporate profit tax rate and to the returns on passive assets relative to total returns. We find clear evidence of a negative average LATE of the CFC legislation on the fixed assets held by German multinationals abroad. We find also evidence of some heterogeneity of LATE according to parametric as well as nonparametric estimates. On average, Foreign assets are estimated to respond by about 10 million Euros in the neighborhood of the intersection of both treatment thresholds. This evidence points to a significant and economically large impact of anti-tax-avoidance legislation on multinational firms’ real activity abroad.
Aaron M. French - One of the best experts on this subject based on the ideXlab platform.
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Relationships between need-pull/technology-push and information security management and the moderating role of regulatory pressure
Information Technology and Management, 2015Co-Authors: Sanghyun Kim, Geuna Kim, Aaron M. FrenchAbstract:Information security management (ISM) has become more important than ever, as the expansion of corporate information systems and the use of networks continue to increase. Many organizations consider ISM an important part of organizational innovation and key to strategic and operational efficiency. Managers require a firm understanding of the behavioral aspect of ISM, particularly of how their firms’ internal and external characteristics affect the ISM process. This study draws on need-pull–technology-push (NP–TP) theories and employs data on information security users to investigate the NP and TP factors influencing the awareness, development, and performance stages of ISM. This study also examines the moderating role of regulatory pressure in those relationships. The research model is tested with data taken from a random sample of global organizations obtained through the Korea Composite Stock Price Index, the Korean Securities Dealers Automated Quotation, and the Korea Foreign Company Association. The results indicate that all NP–TP variables had positive effects on the ISM process (with the exception of perceived benefits). Moreover, regulatory pressure had positive effects as a moderator between ISM awareness and ISM development and performance.