In the past decade, there has been a significant decrease in US corporate tax revenues. Multinational companies have been employing several different techniques of tax avoidance to get around paying corporate taxes. Tax avoidance is used by any large multinational corporation for a variety of reasons. The US has one of the highest corporate tax rates in the world and is seeing many companies relocate their operations abroad to lower their tax expenses. The different methods of tax avoidance are discussed in this thesis, as well as the different reasons behind their use. To understand how companies implement tax avoidance techniques, it is necessary to understand US corporate taxes. I have researched the few key items of US corporate taxes, which are vital to understanding the implementation of tax avoidance techniques. Through different examples you will see how tax avoidance occurs and how it benefits multinational companies.

A research report submitted to the Faculty of Commerce, Law and Management, University of the Witwatersrand, Johannesburg, in partial fulfilment of the requirements for the degree of Master of Commerce (specialising in Taxation) / Tax avoidance is the legal utilisation of the tax regime to one's own advantage, to reduce the amount of tax that is payable by means that are within the law. Tax evasion entails taxpayers deliberately misrepresenting or concealing the true state of their affairs to the tax authorities in order to reduce their tax liability, and includes, in particular, dishonest tax reporting (such as declaring less income, profits or gains than actually earned; or overstating the deductions). The revised general anti-avoidance measures were introduced in the Income Tax Act 58 of 1962 ('the Act') on 2 November 2006 in the form of section 80A to 80L, in order to replace the complicated and confusing as well as ineffective anti-avoidance measures contained in section 103(1). / AC 2018

L'évasion fiscale consiste en l'action du contribuable à obtenir un bénéfice, de manière à réduire ou à éviter le paiement de l'impôt, contrairement aux intentions du législateur, sans pour autant violer la loi. L'évasion fiscale représente un problème particulier pour l'intégrité du système fiscal en matière d'impôt sur les sociétés, un constat justifié par le fait que la lutte contre ce phénomène se trouve dans les programmes politiques des États membres de l'Union européenne, ainsi que dans le Plan d'action concernant l'érosion de la base d'imposition et le transfert de bénéfices de l'OCDE. L'objet de cette thèse, écrite en co-tutelle, est d'analyser dans un premier temps l'état actuel des mesures du système croate de lutte contre l'évasion fiscale internationale en matière d'impôt sur les sociétés, pour le comparer ensuite au système des mesures du droit fiscal français, afin de proposer des solutions d'amélioration du système national. Puisque la diversité des formes que l'évasion fiscale peut prendre nécessite une approche compréhensive, cette recherche sera concentrée non seulement sur l'amélioration du cadre législatif, mais aussi sur l'exécution de la lutte contre l'évasion fiscale. / Tax avoidance is generally used to describe the arrangement of a taxpayer's affairs that is intended to reduce his tax liability in accordance with the letter of the law, but contrary to the intention of the lawmaker. A special problem for the integrity of the tax system is avoidance of corporate tax, the importance of which is reflected in the presence of measures for its curbing in political programmes of EU countries as well as the OECD which elaborated the Action Plan on Base Erosion and Profil Shifting (BEPS). This double degree thesis will investigate the current state of Croatian measures for combatting corporate tax avoidance, by performing a comparative analysis with the French system, in order to propose enhancements of the national system of measures. Given the fact that corporate tax avoidance appears in a multitude of forms and that tackling it requires a comprehensive approach, the research will aim at enhancing not only Croatian material but also procedural tax rules for curbing corporate tax avoidance.

This thesis empirically studies the relation between corporate social responsibility (CSR) and corporate tax avoidance. Based on a sample of 3304 observations between 2002 and 2014, I find that the CSR score of companies is negatively related to their effective tax rate. This indicates that on average, responsible companies are more involved in tax avoidance activities compared to less responsible companies. This result is robust against different sets of control variables. The results of this thesis are contrary towards previous research, where most studies find a negative relation between CSR and tax avoidance. In addition, I examine how four dimensions of CSR are related to corporate tax avoidance and I find that economic performance and environmental performance are positive significant related towards tax avoidance. This indicates that shareholder and client loyalty, as well as resource and emission reduction, relate to a higher extent of corporate tax avoidance.

Taxes are major source of public funds to finance government expenditures. Tax authorities impose different kind of taxes and employ many agents to collect taxes effectively. Some dutiful taxpayers will undoubtedly pay their tax liabilities while many others will not. The Internal Revenue Service in the United States reports that the estimate of income tax liability not collected is about 17, which translates into 345 billion for 2001. It is important to make a distinction between tax evasion and tax avoidance. The distinguishing characteristic of evasion is illegality. Whether the reason for not paying tax liability is avoidance or evasion, economic models of taxation need to be changed in the light of these realities. In this study, I analyze some of the economic problems of tax evasion/avoidance. In the first chapter, I discuss the relationship between number of tax audits, tax administration reform and tax compliance in Turkey. In recent years, many developing countries have carried out reforms in their tax administration to increase their efficiency in collecting taxes. In 2005, the tax authority in Turkey established Tax Office Directorates (T.O.D.s) in 29 provinces for the purpose of controlling the underground economy, improving taxpayer assistance, and increasing auditing efficiency. By using the panel data on province level tax returns, my analysis answers two questions. First, I examine the effect of audits on reported income and reported tax liability. By controlling for the detectibility of evasion and other socioeconomic variables, I find that audits have the same effectiveness in increasing reported income and reported tax liability. Second, I investigate the effect of establishing T.O.D.s in 29 provinces on compliance in those provinces. I find that T.O.D.s are effective at the extensive margin rather than the intensive margin. Thus, establishing T.O.D.s had no significant effect on the compliance level of existing taxpayers while it increased the number of tax returns significantly. In the second chapter, I analyze the excess burden on income tax when tax avoidance matters. I present a simple static labor supply model with endogenous asset choice. Then, I examine how tax avoidance through asset trading a ects the labor supply response and the excess burden of income tax. Furthermore, I discuss the implications of the tax policy analysis and show that a failure to account for avoidance responses may lead to errors when estimating how tax reform affects labor supply, tax revenue, and the welfare cost of taxation. Because of tax avoidance through tax arbitrage, the progressivity of a given tax system will be less than what the formal tax system implies. In the third chapter,we study the Marginal Cost of Funds in the existence of tax evasion. We develop a general equilibrium model of tax evasion, including the expected utility of taxpayers and three different revenue-raising government policies. In this rich model environment, we analytically derive the marginal cost of funds (MCF) for the alternative policy instruments. We consider two main fiscal reforms: the revision in the nonlinear tax scheme and the changes in enforcement mechanism (the audit and penalty rates). First, we derive the MCF for the tax reform and find its key determinants. The derived MCF is greater than the previous ones since it includes a "risk-bearing cost" as well as tax distortion. The reform in enforcement mechanism generates MCFs in different forms. Two more MCFs with respect to audit and penalty rates are presented. Finally, we compare these three different MCFs in numerical example and provide some policy implications. / text

This paper tests the notion that private firms are more tax aggressive than public firms. Tax avoidance measures, e.g. effective tax rates, cannot be used to compare private and public firms when private and public firms have different levels of importance on financial accounting earnings (Hanlon and Heitzman 2010). To disentangle financial reporting incentives from tax aggressiveness, I use the fact that European groups must prepare two sets of financial statements: first, group statements (consolidated), which provide information to investors, and, second, individual statements (unconsolidated), which are used for legal purposes, but not to inform investors. Since in individual statements financial reporting incentives do not vary between public and private firms, I use these effective tax rates to compare private and public firms. My findings show that public, not private, firms are more tax aggressive, as the effective tax rates of public firms are lower in individual and group statements. (author's abstract) / Series: WU International Taxation Research Paper Series

This paper empirically tests a theory laid out in Scholes et al. (2015, p. 315) that the U.S. worldwide tax system reduces the incentive of U.S. parent companies to be tax aggressive in their foreign subsidiaries. Investors subject to a worldwide tax system pay taxes on their worldwide income, regardless of the origin thereof. Therefore, a U.S. investor pays the difference between the effective tax payment abroad and the higher U.S. statutory tax when profits are repatriated. In contrast, investors subject to territorial tax systems gain the full tax savings from being tax aggressive abroad. Our results show that U.S.-owned foreign subsidiaries have a by 1.2 percentage point higher average GAAP effective tax rate (ETR) compared to subsidiaries owned by foreign investors from countries with a territorial system. We contribute to the literature by showing a mechanism, other than cross-country profit shifting, why U.S. multinational companies have higher GAAP ETRs than multinationals subject to territorial tax systems. (authors' abstract) / Series: WU International Taxation Research Paper Series

This paper examines how economic, environmental and social CSR activities are related to tax avoidance. Subsequently, this study examines whether internationalization moderates the relationship between the different CSR activities and tax avoidance. A matched sample of 266 firm-year observations was formed; equally split between tax avoidant firms as well as tax compliant firms by employing a novel approach to identify corporate tax avoidance based on tax disputes. The logit regression results shows that the more firms engage in social CSR activities the more likely they are to avoid taxes. Moreover, the main regression also supports the positive moderation effect of internationalisation on the relationship between social CSR and tax avoidance.

We investigate whether and to what extent the adoption of an intellectual property box increases innovative activity and the extent to which different types of firms benefit financially. We examine the adoption of the intellectual property box in Belgium because it allows us to cleanly identify the impact on innovative activity and effective tax rates. Our results indicate an overall increase in innovative activity as proxied by patent applications, grants, and highly-skilled employment, at the expense of patent quality. We also provide evidence that firms with patents on average enjoy 7.2% to 7.9% lower effective tax rates, with the greatest financial benefits accruing to multinational firms compared to domestic firms. Within multinational firms, those without income shifting opportunities appear to benefit more than other multinationals with income shifting opportunities. / Series: WU International Taxation Research Paper Series

The objective of this thesis is to place trust fund into the system of tax law and the analyse of this position from different angles. The main objective is to describe, how are trust funds and the persons connected with them, taxed. One of the aims of this thesis is to show trust funds within a broader context and therefore it describes the tax aspects of English common law trust as well. Common law trust can be considered as a role model for institute like the Czech trust fund. The thesis therefore consists of two parts - trust and trust fund. The first chapter describes historical development of trusts and illustrate how was this development influenced by then tax legislature. Also, this chapter explains some aspects of English law, with focus on difference between common law and equity. The grasp of the difference between these parallel systems is essential for the understanding of trust. The second chapter deals mainly with substantive aspects of trust. It strives to answer the question, what is trust and how can we definite it. It also shows, how the tax legislature defines trust and connected person for tax purposes. It is also briefly mentioned the duty of trust to register into newly established trust register. The third chapter deals with taxation of trust itself. Different types of trusts and...