It is well documented in existing literature that firms manipulate earnings before IPOs (initial public offerings) and SEOs (seasoned equity offerings). This study contributes to prior research by being the first to examine whether fiscal support from local governments has impact on the earnings management behavior of Chinese listed firms. Using data from firms that conduct IPOs and SEOs from 1997 to 2006, I find that firms are less likely to manipulate earnings prior to the offerings if they enjoy more income tax savings attributed to the preferential tax favor or more financial subsidy from the local governments. The findings of the study have important policy implications. Noticeably, the new Enterprise Income Tax Law effective from 1 January, 2008 abrogates the original tax system that allows various preferential tax rates for firms of different properties and stipulates a 25% enterprise income tax rate for all firms in China. Given the abolishment of the preferential tax favor, local governments lose a potent avenue of lending fiscal support to the listed firms. To this end, based on the findings in this study, I expect that the opportunistic earnings management by listed firms will probably be aggravated after the new income tax law is duly enforced.

Since the 1979 economic reforms, China has been characterized by a rapid increase in international trade and an inflow of foreign direct investment. Foreign investment enterprises (FIEs) play an increasing important role in the Chinese economy and are substantially engaged in transactions with affiliates outside China. Therefore, international transfer pricing in China has become a significant issue. Empirical research on international transfer pricing has focused on multinational corporations (MNCs) operating in developed countries. However, it is difficult to generalize their findings to MNCs operating in developing countries as the business environment of developing countries is quite different from that of developed countries. Existing literature identifies that due to differences in the business environment between developed and developing countries, the tax factors which are important in developed countries should not be over-emphasized in developing countries. Some nontax factors such as foreign exchange control and restrictions on profit repatriation which may not be important in developed countries are nevertheless important in developing countries. However, empirical studies on international transfer pricing in developing countries are relatively scare. Furthermore, there have been no empirical studies that examine the relationships between management’s perception of the importance of environmental variables and management’s choice of international transfer pricing methods in developing countries, or which analyze the tax and nontax cost trade-off for tax evasion via international transfer pricing in developed or developing countries. The objective of this thesis is to provide a comprehensive empirical study on international transfer pricing in China from the perspectives of both taxpayer and the tax authority. The results of this thesis indicate that the more important the management perceives the interest of local partners and the maintenance of a good relationship with host government to be, the more likely it is that the FIE will adopt a market-based transfer pricing method. On the other hand, the more important the management perceives foreign exchange controls in transfer pricing decisions to be, the more likely it is that the FIE will choose a cost-based transfer pricing method. The research results also reveal that based on a tax and non-tax cost trade-off analysis, wholly foreign-owned enterprises, cooperative joint ventures and exportoriented FIEs are more likely to be selected for transfer pricing audits in China than equity joint ventures and domestic -market oriented enterprises. Some explanations for this result are the lack of monitoring by Chinese local partners in certain FIEs and the opportunity for transfer pricing manipulations. The results of this thesis have important policy implications for foreign investors carrying on business in China, the Chinese tax authorities as well as academic researchers. My research results should help foreign investors to have a better understanding of the tax and the nontax factors in formulating transfer pricing policies in China. The results should also help tax authorities tackle tax audit problems more effectively and in setting tax audit guidelines on related party transactions. Further, this thesis should contribute to the establishment of a more comprehensive theoretical framework of international transfer pricing in developing countries. It also empirically demonstrates the applicability of the tax and nontax cost theory in the context of international transfer pricing.

Thesis (Ph. D.)--University of Texas at Austin, 2006. / Vita. Includes bibliographical references.

This dissertation contains three essays. The first essay examines the response of equity values to the announcement of a decrease in the capital gains tax rate. The Taxpayer Relief Act of 1997 reduced the long-term capital gains tax rate. News of this rate reduction reached investors in late April to early May of 1997. During the week of this event, firms with appreciated stock positions, average holding periods of at least one year, and individual marginal investors reported lower returns than companies lacking one or more of these characteristics. The second essay builds on recent research reporting that firms establish target capital structures by weighing the costs and benefits of debt and that adjustment costs dictate how rapidly companies move toward optimal leverage ratios. If tax considerations impact debt structures adjust more rapidly than companies below the goals because low-tax firms have less need of interest deductions to decrease tax burdens and, thus, sacrifice less tax benefit when retiring debt. The third essay demonstrates that manufacturing firms manipulate production to manage earnings and examines whether tax incentives magnify or temper this strategy. Companies that exceed the quarterly consensus analyst forecasts absent the earnings effects of discretionary inventory changes cut production and create an earnings cookie jar for future quarters. For this sub-sample, companies make larger discretionary inventory decreases as the marginal tax rates rise in the fourth quarter relative to the first three quarters. In contrast, the sub-sample of firms that miss income goals without manipulating production use discretionary inventory increases to enhance earnings and potentially reach benchmarks. Higher tax rates do not impede miss firms from managing earnings upward; however, considerations of tax timing dissuade these companies from opportunistically manipulating production in the fourth quarter.levels of the firms, taxes are also likely to influence the rates of adjustment to target levels. Among high-tax firms, companies below the optimal leverage ratios respond more quickly than companies above the targets because high-tax firms can better utilize the interest deductions generated by issuing additional debt to reduce tax liabilities. Among low-tax firms, companies above the target capital

This dissertation contains three essays. The first essay examines the response of equity values to the announcement of a decrease in the capital gains tax rate. The Taxpayer Relief Act of 1997 reduced the long-term capital gains tax rate. News of this rate reduction reached investors in late April to early May of 1997. During the week of this event, firms with appreciated stock positions, average holding periods of at least one year, and individual marginal investors reported lower returns than companies lacking one or more of these characteristics. The second essay builds on recent research reporting that firms establish target capital structures by weighing the costs and benefits of debt and that adjustment costs dictate how rapidly companies move toward optimal leverage ratios. If tax considerations impact debt structures adjust more rapidly than companies below the goals because low-tax firms have less need of interest deductions to decrease tax burdens and, thus, sacrifice less tax benefit when retiring debt. The third essay demonstrates that manufacturing firms manipulate production to manage earnings and examines whether tax incentives magnify or temper this strategy. Companies that exceed the quarterly consensus analyst forecasts absent the earnings effects of discretionary inventory changes cut production and create an earnings cookie jar for future quarters. For this sub-sample, companies make larger discretionary inventory decreases as the marginal tax rates rise in the fourth quarter relative to the first three quarters. In contrast, the sub-sample of firms that miss income goals without manipulating production use discretionary inventory increases to enhance earnings and potentially reach benchmarks. Higher tax rates do not impede miss firms from managing earnings upward; however, considerations of tax timing dissuade these companies from opportunistically manipulating production in the fourth quarter.levels of the firms, taxes are also likely to influence the rates of adjustment to target levels. Among high-tax firms, companies below the optimal leverage ratios respond more quickly than companies above the targets because high-tax firms can better utilize the interest deductions generated by issuing additional debt to reduce tax liabilities. Among low-tax firms, companies above the target capital

Issued also as the author's Thesis (Ph. D.), Columbia University. / Bibliography: p. 296-299.

Inaug.-diss. - Erlangen.

Thèse--Faculté de droit de Paris.

Thesis (Ph. D.)--University of Queensland, 2002. / Includes bibliographical references.

The primary aim of a dissertation is to try to discover information that could assist in solving a particular problem at hand. The object of this dissertation is to determine the approach by our courts to apportionment of expenditure in terms of section 11(a) read with section 23(g) of the Income Tax Act No 58 of 1962. A single expenditure incurred for more than one purpose poses a problem when deduction of such an expenditure, is sought by a taxpayer. The problem that ttie courts have always encountered when dealing with the deductibility of expenditure incurred for a dual purpose, is that there is no provision in the Income Tax Act that directs what to do when faced with such a problem. The courts have always chosen apportionment of expenditure as a solution to the deductibility of expenditure incurred for more than one purpose, one such purpose being for tax purposes and the other being for non tax purposes. Apportionment of expenditure is used as a device to allocate part of the expenditure, which was incurred to produce income, as taxable expenditure, and another part of that expenditure which was incurred to produce non-taxable income, as non-deductible expenditure. This dissertation seeks to find out whether courts do take into consideration the provisions of the Income Tax Act applicable to the deduction of expenditure when called upon to make a decision on a particular case. The South African Revenue Services use apportionment of expenditure where it deems appropriate and the courts have never opposed it. The Legislature, which is responsible for the enactment of the act, seems to be happy to lie low, and allow the courts to dominate in handling the disputes that arise as a result of expenditure incurred with a dual purpose. It has been suggested that whilst the Income Tax Act does not provide any direction in situations where the deductibility of dual purposes expenditure is in dispute, apportionment is implied in the terms of section 11(a) read with section 23(g) of the Income Tax Act no 58 of 1962. The main aim of this research is to establish whether the path taken by the courts is the correct one in terms of section 11(a) and section 23(g) of the Income Tax Act no 58 of 1962. It is hoped that this work will be of assistance to both The South African Revenue Services and the taxpayers at large in terms of understanding that the courts are within the bounds of the Act. / Thesis (M.Com.)-University of KwaZulu-Natal, 2004.