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International Tax and Public Finance
Article . 2021 . Peer-reviewed
License: CC BY
Data sources: Crossref
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International Tax and Public Finance
Article
License: CC BY
Data sources: UnpayWall
SSRN Electronic Journal
Article . 2020 . Peer-reviewed
Data sources: Crossref
EconStor
Article . 2021
License: CC BY
Data sources: EconStor
EconStor
Research . 2020
Data sources: EconStor
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Substitution Across Profit-Shifting Methods and the Impact on Thin Capitalization Rules

Authors: Gideon Goerdt; Wolfgang Eggert;

Substitution Across Profit-Shifting Methods and the Impact on Thin Capitalization Rules

Abstract

AbstractThin capitalization rules limit firms’ ability to deduct internal interest payments from taxable income, thereby restricting debt shifting activities of multinational firms. Since multinational firms can limit their tax liability in several ways, regulation of debt shifting may have an impact on other profit shifting methods. We therefore provide a model in which a multinational firm can shift profits out of a host country by issuing internal debt from an entity located in a tax haven and by manipulating transfer prices on internal goods and services. The focus of this paper is the analysis of regulatory incentives, $$(i)$$ ( i ) if a multinational firm treats debt shifting and transfer pricing as substitutes or $$(ii)$$ ( i i ) if the methods are not directly connected. The results provide a new aspect for why hybrid thin capitalization rules are used. Our discussion in this paper explains why hybrid rules can result in improvements in welfare if multinational firms treat methods of profit shifting as substitutes.

Country
Germany
Keywords

thin capitalization rules, 330, ddc:330, Profit shifting methods, 332, K3, substitution, H2, H20, profit shifting methods, K30, ddc:340, Thin capitalization rules, H70, H7, Substitution

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    selected citations
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    This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
    7
    popularity
    This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
    Top 10%
    influence
    This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
    Top 10%
    impulse
    This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
    Average
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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
7
Top 10%
Top 10%
Average
Green
hybrid