This thesis argues that one type of multinational entity – the multinational bank – poses particularly significant challenges to the international tax regime in terms of its current profit allocation rules. Multinational banks are a unique subset of multinational entities, and as a consequence of their unique traits, the traditional international tax regime foes not yield an optimal interjurisdictional allocation of taxing rights. The opportunity for tax minimisation, achievable because of the unique traits, and realised through exploitation of the traditional source and transfer pricing regime, results in a jurisdictional distribution of taxing rights which does not reflect economic reality. There are two distinct ways in which the traditional international tax regime fails to reflect economic activity. The first way that economic activity may not be reflected in the distribution of the taxing rights to income from multinational banking is through the application of traditional source rules. The traditional sources rules allocate income where transactions are completed rather than where the intermediation services are arranged. As a result of their unique commercial role as financial intermediaries, by separating intermediary economic activity from legal transactions with third parties, multinational banks may distort the true location of the activity giving rise to income. The second way in which the traditional tax regime may fail to reflect economic activity is through the traditional transfer pricing regime requiring related or internal transaction to be undertaken at an arm’s length price. The arm’s length pricing requirement is theoretically deficient in its failure to recognise the highly integrated nature of multinational banking. In practice, the arm’s length pricing requirement is also difficult, if not impossible, to apply to multinational banks because of the requirement of comparability. The difficulties associated with the current model have resulted in a subtle move by multinational banks towards global formulary apportionment. This thesis concludes that, for the international taxation of multinational banks, the current source regime should be replaced with a system that allocates profits for tax purposes on the basis of income source, with source determined using a unitary taxation or global formulary apportionment system. It is argued that global formulary apportionment is a theoretically superior model that provides both jurisdiction to tax and allocated profits on the basis of the economic activity that generates the income.

The world has been challenged by the COVID-19 pandemic since 2020. The pandemic affected all businesses, and the banking sector was no exception. Within this context, efficient change management (CM) is crucial to keep up with the changing business environment. Previous research has extensively covered the planned and emergent approaches to CM. However, the authors found that the perspective of complex organisations and their effect on change was missing. The purpose of the study was to develop a deeper understanding of how the internal processes were challenged during the COVID-19 pandemic, following a Scandinavian bank in their change to open a sister department in Vilnius. To study this, the authors conducted 12 semi-structured interviews with employees of Bank XYZ, from Vilnius and Stockholm. Kotter’s 8-step model and the complexity theory were combined and used as the conceptual framework.  The conclusion shows that the pandemic challenged three different aspects, communication, motivation, and new ways of working. These aspects challenged the traditional view of CM, which is viewed as static. The nonlinearity of CM processes is more present in disruptive changes such as the COVID-19 pandemic.

Diss.Stockholm : Handelshögsk.

本文探討台灣銀行業進入東南亞國家的因素，著重於從理論假設到實證研究，先以跨國銀行理論作為框架提出假設，接著利用實證方法來分析追隨客戶的動機可否充分解釋台灣銀行業的擴張行為？又或者是折衷理論之解釋較為全面？最後對於實證結果進行分析，研究發現：追隨客戶、地主國國家的經濟發展、地主國的融資及母行本身的條件是影響台灣銀行業者跨國經營的主要因素。 / This paper analyze the determinants of the overseas physical presences of Taiwanese banks in Southeast Asia. We focus on the process of from theoretical hypotheses to empirical studies. First, we propose hypotheses based on the theory framework of multinational bank, and then, the multiple regression models are adopted and we investigate whether the “follow-the-client’’ hypothesis is held？Or can the test results in views of eclectic theory explain Taiwanese banks’ behavior more comprehensively. The results of this paper are as follows: following their customers, the host countries’ economy, the host countries’ financing market, and the parent banks’ specific qualities are the main factors affecting the number of presences Taiwanese banks in Southeast Asia.