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Pay for tax certainty? Advance tax rulings for risky investment under multi-dimensional tax uncertainty

Authors: Chen, An; Hieber, Peter; Sureth, Caren;

Pay for tax certainty? Advance tax rulings for risky investment under multi-dimensional tax uncertainty

Abstract

In this study, we use advance tax rulings (ATR) to investigate the impact of fee-based tax certainty on risky investment decisions of a firm under both cash flow and tax uncertainty. We model and analyze the multi-dimensional nature of tax uncertainty from tax reforms and tax audits in expected tax rates, tax bases, and in conjunction with loss offset restrictions. A tax au-thority can provide tax certainty by offering ATRs and charging an ATR fee. The fee imposes costs on firms. We determine the critical ATR fee range in which the ATR is acceptable for both the firm and tax authority. Gener-ally, we find the ATR allows the firm to take on riskier investments. If the ATR is employed in an environment with a generous tax loss offset policy, the ATR's inducement effect on risky investments is even strengthened. We identify settings in which the tax authority is willing to charge zero or even negative ATR fees. Negative fees can be interpreted as enhanced services to taxpayers that reduce taxpayers' compliance costs. Surprisingly, we find that an ATR is particularly effective for firms with low risk aversion. Our findings suggest that ATRs can effectively fight tax uncertainty and stimulate investment. However, their effectiveness crucially depends on tax system features such as loss offset restrictions and the ATR fee.

Keywords

optimal investment, cash flow uncertainty, loss offset provisions, advance tax ruling, ddc:330, M41, H25, M42, M48, optimal fee, tax uncertainty, G11

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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!
0
Average
Average
Average
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