iv Abstract The thesis focuses on base erosion and profit shifting (BEPS) and resulting corporate income tax gains or losses. I first estimated profit shifting semi-elasticity using database of firm-level financial data. Subsequently I used these estimates to calculate corporate income tax gains or losses for individual countries. I estimate several models to see how much the semi-elasticity depends on specification and what affects it. The evidence suggests that companies do shift profits to countries with lower tax rate. The estimated overall profit shifting semi-elasticity ranges from 1.524 to 3.695 for different specifications of the benchmark model. Semi-elasticity of individual countries increases with financial secrecy score. Using statutory tax rate yields stronger results than using country-level effective tax rates calculated from the financial data. The estimated effect on government revenue ranges from 12% loss to 23% gain of corporate income tax revenues. In the sample of 53 countries with sufficient number of observations this translates to overall loss 48 billion US dollars. JEL Classification F23, F68, G38, H25, H26, H87 Keywords base erosion, profit shifting, corporate income tax, financial secrecy Author's e-mail michal.petrous@gmail.com Supervisor's e-mail jansky@fsv.cuni.cz

Submitted by Marlene Aparecida de Souza Cardozo (mcardozo@pucsp.br) on 2016-10-28T10:59:11Z No. of bitstreams: 2 Raquel Arruda Soufen - Prefaciais.pdf: 13655 bytes, checksum: c93308d746e3b4103b134d2f1ecced32 (MD5) Raquel Arruda Soufen - Texto.pdf: 299295 bytes, checksum: b2046ce22cb6854309399044d95e37bf (MD5) / Made available in DSpace on 2016-10-28T10:59:11Z (GMT). No. of bitstreams: 2 Raquel Arruda Soufen - Prefaciais.pdf: 13655 bytes, checksum: c93308d746e3b4103b134d2f1ecced32 (MD5) Raquel Arruda Soufen - Texto.pdf: 299295 bytes, checksum: b2046ce22cb6854309399044d95e37bf (MD5) Previous issue date: 2016-03-15 / This study aims to analyze the recommendations proposed by the Organization for Economic Cooperation and Development ("OECD") together with the G20, with regard to combating base erosion profit split ("BEPS"). The study will be developed under the Brazilian legislation, and will examine how these guidelines can be implemented in Brazil, and if they could not, whether such guidelines would impact in any way our rules. In addition, it will be demonstrated that, despite the OECD's recommendations have not binding on Brazil, the BEPS's resolutions end up influencing the decisions of Brazilian multinationals / O presente estudo visa estudar as medidas propostas pela Organização e Cooperação para o Desenvolvimento Econômico ("OCDE"), conjuntamente com o grupo G20, no que tange ao combate à erosão de base tributária ("BEPS"). O estudo será desenvolvido sob o pronto de vista do sistema tributário brasileiro, e irá analisar como tais medidas podem ser aplicadas no Brasil, e em caso negativo, se tais medidas repercutiriam na legislação brasileira. Adicionalmente, buscar-se-á demonstrar que, apesar das recomendações da OCDE não terem caráter vinculante para o Brasil, as resoluções do BEPS acabam influenciando as decisões das empresas multinacionais brasileiras

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In view of the adopted SDGs in 2015 and their focus on domestic resource mobilisation, this diploma thesis attempts to fulfil two main objectives. First, it aims to describe and analyse the current tax system often labelled not only by developing states as unfit for the 21st century's globalized economy. Second, it tries to provide deeper understanding of reasons that lead certain countries not to support the creation of a UN Tax Body, the only platform where all countries could participate in the negotiating of tax harmonization on an equal footing. Three hypotheses based on a neorealist, liberal and functional regime theory are put forward. Using data obtained from interviews conducted with delegates at the UN, it can be concluded that the organisational infrastructure is the power reflection. While the OECD BEPS mechanism is recognised by many as efficient and sufficient, this is possible due to the enabling power relations that exclude more than hundred developing countries from the negotiation of international tax rules. It can thus be concluded that the current OECD mechanism does not address existing policy loopholes that cause losses to developing countries. To match the SDGs' rhetoric with reality, policy-makers should create a more inclusive and universally agreed on standard-setting...

This study aimed to assess the determinants and deterrents of profit shifting, which can occur as a result of corporate income tax competition, with a view to aid in collecting sufficient tax revenue to meet public spending requirements. The study theoretically and empirically analysed the effectiveness of the introduction of the South African transfer pricing regulations on deterring the occurrence of profit shifting in South Africa using annual financial information of South African parented multinational enterprises for the period 2010 – 2017. The study established that the implementation of transfer pricing regulations resulted in a reduction in profit shifting that became increasingly more prominent as the rules became stricter. Based on the findings of the study, it is recommended that the South Africa government should allocate sufficient resources to ensure that the transfer pricing regulations are being adhered with an aim to reduce profit shifting from South Africa. / Economics / M. Com. (Economics)