Many publishers use an honor system for selling newspapers in the street. We conducted a field experiment to study honesty in this market, finding that a moral reminder increases the level of honesty in payments, whereas the same message has no effect on whether one is honest. Reminding customers of the legal norm has no effect. We argue that these results are consistent with a preference for honesty, based on an internalized social norm. Auxiliary evidence suggests that the moral message remains effective when it is posted for longer periods, and even when it is removed again. (authors' abstract)

This paper uses micro-level data from a nationally representative survey of 22,000 individuals in 14 Eastern European countries to investigate the effects of institutional, social, and individual factors on taxpayers' perceptions of power, motivations to comply, and non-compliant behaviors. The results indicate that institutional, social, and individual aspects shape taxpayer behavior: attitudes of peers, individual compliance norms, and the tax burden impact on non-compliance. Moreover, I find several effects of the subjective appraisal of the interaction with tax administrations. Positive experiences strengthen perceptions of power and intrinsic motivations to comply. They also increase the propensity to report non-compliant behavior in the past, suggesting educational effects of taxpayer services and tax audits. (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 aims at providing a comprehensive overview of existing literature on the topic of comparability adjustments. Based on existing literature the most commonly used adjustments can be categorized in two broad categories: "accounting and financial risks adjustments" and "strategic/market adjustments". With the exception of working capital adjustments, the lack of guidance and recognized standardized application will quite possibly lead to continued discrepancies in their use. Taxpayers continue to struggle with the immense amount of documentation as well as justification requirements when it comes to adjustments, as there is no clear path to follow and very few practical application examples, which would unify the application of adjustments. As seen, even though the topic of comparability adjustments has been around since before the first version of the OECD TP Guidelines, the topic is yet to be fully explored in both official guidance as well as literature, research and especially practical tools. / Series: WU International Taxation Research Paper Series

This paper studies the evasion of TV license fees in Austria. We exploit border differentials to identify the effect of fees on evasion. Comparing municipalities at the low- and high-fee side of state borders reveals that higher fees trigger significantly more evasion. Our preferred estimator indicates that a one percent increase in fees raises the evasion rate by 0.3 percentage points. The positive effect of fees on evasion is confirmed in different parametric and non-parametric approaches and survives several robustness checks.

Using a game theoretical setting, this paper studies how a multinational company's (MNC) choice of using one set (OSB) or two sets of books (TSB) is affected by a strategically acting tax auditor (TA). First, a divisionalized MNC with a producing division in a low tax country and a selling division in a high tax country chooses either OSB or TSB. With OSB, the unique transfer price coordinates the quantity decision and determines the tax payments. With TSB, two transfer prices are used for both tasks. Second, a TA may audit the MNC's transfer prices. It turns out that the TA's bargaining power and his personal audit costs critically influence the MNC's transfer pricing decision. For a low bargaining power and low audit costs, the MNC keeps OSB with positive probability. When the TA's bargaining power is high, the negotiation benefits from using a single transfer price are outweighed by the costs of a reduced flexibility. Then, the MNC keeps TSB with either tax aggressive or compliant reported transfer prices. In addition, a raise in the tax difference induces less tax aggressive behavior. Intuitively, tax aggressiveness should be even more attractive in this case. This intuition is not true in our setting since the TA's audit probability increases and, thus, makes profit shifting less attractive. / Series: WU International Taxation Research Paper Series

Large multinational companies are regularly suspected of using transfer pricing of intangibles to shift profits from high- to low-tax jurisdictions. We study the optimal transfer prices while endogenizing the location choice of intangibles and considering spillovers. In line with the initial intuition, we find that multinationals locate their intangibles in low-tax jurisdictions and deploy royalty flows to minimize tax payments. However, if multinationals face a trade-off between tax minimization and efficient spillover internalization, the so-called "home bias" might occur. Then, for a large spillover, the intangible is optimally located in the high-tax domestic country. This leads to less severe investment distortions because the spillover is internalized. In addition, the model predicts that curtailing profit shifting possibilities can either harm or facilitate multinationals' overall investments. This depends heavily on unobservable factors such as the underlying accounting system. Therefore, our analysis highlights challenges for the anti-avoidance legislation of governments. / Series: WU International Taxation Research Paper Series

I examine whether and to what extent tax uncertainty affects a firm's dividend payouts. Based on the argument that tax uncertainty impairs the persistence and predictability of after-tax cash flows, I hypothesize and find that firms with greater tax uncertainty exhibit a lower probability of dividend payouts. The effect of tax uncertainty is stronger in the presence of financial constraints and weaker for firms that distribute dividends to alleviate agency conflicts. Furthermore, I find a negative effect of tax uncertainty on dividend levels, which is moderated by the costs of dividend reductions. These results are economically meaningful as a one standard deviation higher tax uncertainty leads to a 9.9 percentage point lower probability and a $23.6 million reduction in dividend payouts. Taken together, my findings document a real effect of tax avoidance and contribute to the understanding of interactions between uncertain tax avoidance and a firm's financial ecosystem. / Series: WU International Taxation Research Paper Series

This study combines macro and micro data to quantify the revenue effects of double tax treaties. First, drawing on administrative information, the study estimates the tax sensitivity of income flows (dividend, interest, and royalty payments) at an aggregate level. The analysis finds important direct revenue costs linked to treaty restrictions on taxing rights, especially for flows into a few major investment hubs. However, high elasticities of income flows also suggest that increases in withholding rates at the individual treaty partner level would not necessarily result in more revenue collection. Second, the study uses firm- level information to estimate the sensitivity of reported profitability to changes in the relevant treaty network. The analysis of the reported earnings of multinational enterprise affiliates in Ukraine suggests that the ownership structure and operations with affiliates in certain jurisdictions explain reported profitability, and should thus receive increased attention in risk assessment and transfer pricing audit activities. / Series: WU International Taxation Research Paper Series

This paper investigates the effects of double tax treaties (DTTs) on foreign direct investment (FDI) after controlling for their relevance in the presence of treaty shopping. DTTs cannot be considered a bilateral issue, but must be viewed as a network. We define tax distance as the cost of channelling corporate income from one country to another and, by considering treaty shopping through intermediate jurisdictions, we calculate the shortest (i.e. the cheapest) distance between any two countries. We show that relevant tax treaties-which reduce the direct tax distance both over domestic law and the entire existing treaty network-will increase FDI by about 18%.