Abstract: For many enterprises, the delocalization of a part or the totality of their supply chain to low cost countries is the best way to reduce costs and remain competitive against the growing globalized market. This new tendency is driven by logistics advantages, as well as, financial and tax discount offered by the host countries. The objective of this article is to examine the new financial challenges introduced by the project of base erosion and profits shifting (BEPS), published in 2015, and also their impact on the decision of delocalization. In fact, the strategy adopted by multinational firms for determining the transfer price (TP) of goods and services, as well as the shared amount of revenues and expenses have a major impact upon group profit and may contribute to divergent results. In order to get more profit, a coherent decision of delocalization should be based on an evaluation of all the operational and financial characteristics associated with such movement. Therefore, it is interesting to model these new constraints and integrate them in a more global decision model. The established model will enable to measure how much these financial constraints impact the decision of delocalization and will give new helpful directives for enterprise managers.
Abstract: Countries in recession, among them Croatia, have
lower tax revenues as a result of unfavorable economic situation,
which is decrease of the economic activities and unemployment. The
global tax base has decreased. In order to create larger state revenues,
states use the institute of tax authorities. By controlling transfer
pricing in the international companies and using certain techniques,
tax authorities can create greater tax obligations for the companies in
a short period of time.
Abstract: The relation between taxation states and foreign direct
investment has been studied for several perspectives and with states
of different levels of development. Usually it's only considered the
impact of tax level on the foreign direct investment volume. This
paper enhances this view by assuming that multinationals companies
(MNC) can use transfer prices systems and have got investment
timing flexibility. Thus, it evaluates the impact of the use of
international transfer pricing systems on the states- policy and on the
investment timing of the multinational companies. In uncertain
business environments (with periodical release of news), the
investment can increase if MNC detain investment delay options.
This paper shows how tax differentials can attract foreign direct
investments (FDI) and influence MNC behavior. The equilibrium is
set in a global environment where MNC can shift their profits
between states depending on the corporate tax rates. Assuming the
use of transfer pricing schemes, this paper confirms the relationship
between MNC behavior and the release of new business news.
Abstract: Cost contribution arrangements (CCAs) and Cost
sharing agreements (CCAs) belong to the tools of modern finance
management. Costs spend by associated enterprises on developing
producing or obtaining assets, services or rights (in general -
benefits) are used for tax optimizing too. The main purpose of joint
research and development, producing or obtaining benefits is to
lower these costs as much as possible or to maximize the benefits. In
this article is mentioned the problematic of transfer pricing and arm's
length principle with connection of CCAs, CSAs. Next, there is
mentioned how to settle participation shares of the total cost and
benefits contributions with respect to the OECD Transfer pricing for
MNEs Guidelines and with respect to other significant regulations.