Thursday , June 11, 2026 |   06:22:34 IST
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI
About Us Contact Us Newsletters
 
NEWS FLASH
 
I-T - Subscription-based access to journals, e-magazines or databases is not FTS, unless content is specifically rendered for user's individual requirements: ITAT (See Breaking News) TP - Revenue-neutral related party payments do not justify transfer pricing adjustment where there is no tax arbitrage: ITAT (See Breaking News) I-T - Payments made to foreign telecom operators for data transmission services outside India are not royalty under DTAA so as to trigger withholding u/s 195: ITAT (See Breaking News) TP - Persistent losses in three successive assessment years is sufficient ground for exclusion of comparable: ITAT (See Breaking News) TP - Failure to first issue a draft assessment order renders final assessment order invalid & without jurisdiction: ITAT (See Breaking News) I-T - Once established that assessee had sufficient explained foreign income & remittances are duly sourced from such income, consequent investment in immovable property cannot be deemed unexplained merely because certain payments were not fully verifiable at assessment stage: ITAT (See Breaking News) DTAA - Payment made for offshore supply cannot be construed as FTS in absence of make available clause or no transfer of technology: ITAT (See Breaking News) TP - Capital contribution to wholly owned subsidiary cannot be re-characterized as loan in absence of debt-like features: ITAT (See Breaking News) I-T - Internal allocation of expenditure by one branch/head office to another branch of same enterprise cannot be disallowed u/s 40(a)(i) in absence of payment so as to trigger Sec 195: ITAT (See Breaking News) I-T - Non-obstante clause u/s 144C(13) does not exclude operation of Sec 153 as whole: ITAT (See Breaking News) Industrial dole-outs reach a new peak since global financial crisis: OECD (See TII Brief) I-T - Time limit prescribed u/s 153 has to be adhered to and both Section 144C and 153 are mutually inclusive and interdependent: ITAT (See Breaking News) I-T - Presence of notwithstanding clause in Section 144C(13) would not exclude operation of Section 153: ITAT (See Breaking News) I-T - Receipts from sale of Renewable Energy Certificates are capital receipts and are not taxable as revenue income: ITAT (See Breaking News) TP - Section 94B applies only when debt is from non-resident AE and no corresponding restriction exists for resident AE borrowings: ITAT (See Breaking News) TP - Functional dissimilarity, turnover filter, and abnormal profit calls for exclusion of comparable: ITAT (See Breaking News) TP - TPO cannot question commercial expediency once expenditure is shown to have been incurred for business purposes; assessee must nevertheless establish that services were indeed rendered: ITAT (See Breaking News) TP - Comparables selected in previous assessment years need to be included in current year as well, in identical facts & circumstances: ITAT (See Breaking News) TP - Adjustment on account of interest paid on NCDs cannot be made by ignoring internal CUP: ITAT (See Breaking News)
 
TII SEARCH
 
 
   
Home >> News Brief
 

IMF WP Gives New Insight on Impact of Profit-Shifting by MNCs
By TII News Service
Jan 08, 2020 , Washington DC

    

A Working Paper (WP) from International Monetary Fund (IMF) has concluded that profit-shifting opportunities unambiguously reduce the cost of capital in all countries. This is irrespective of whether they charge higher or lower taxes than the global average. WP has also observed that there is no impact on countries that charge exactly the global average rate.

WP says: "Hence profit-shifting raises global capital stocks. That does not necessarily imply that it is also efficient, as it creates a distortion between the purely domestic and international parts of the economy, leading to a shift of capital from purely domestic to multinational firms.8 The impact on welfare and optimal behaviour by governments is ambiguous, however. While jurisdictions with relatively low taxes are likely to gain revenues and capital, high-tax countries are likely to gain capital but lose revenue".

WP captioned 'The Impact of Profit Shifting on Economic Activity and Tax Competition' was issued a fortnight back.

It says: "Considering that tax bases may differ in the degree of mobility- or their access to profit-shifting opportunities - reveals a mechanism through which curbing profit shifting will have an ambiguous impact on tax revenues and welfare, similar to the ambiguous results about the benefits of permitting special regimes for mobile capital".

WP notes that Given the ambiguity of many of the findings, the recent strength of international efforts at curbing profit shifting may appear surprising. It points that there are many important aspects that can't analysed through simple models.

Allowing effectively lower taxation of mobile activities, for instance, may put local businesses at a competitive disadvantage, creating incentives for mergers with firms that have global activities, even without a business reason. Politically it could also be costly to charge lower effective taxes to mobile businesses that often are particularly profitable.

WP has used a simulation model to assess the impact of profit-shifting on investment, revenues, and government behaviour.

According to WP, "The illustrative use of the simple model also revealed the difficulty in assessing separately the impact of changes to tax rates or the ease of profit shifting on investment and revenues. If this is complicated already in a very simple model, it must be much more so in practice, where many further channels and interactions exist. So, while countries may indeed have more than one instrument at their hand to react to competitive pressures, it is not easy for them to determine the optimal strategy."

Multinational corporations (MNCs)often reduce their global tax liabilities through profit shifting activities. Typical examples include transfer price manipulation, intra-company debt, and the strategic location of intangible assets, such as intellectual property (IP). There is plenty of empirical evidence that reported profits by multinationals indeed respond to international tax differentials.

 
 
INTL TAXATION INTL MISC TP FDI LIBRARY VISA BIPA NRI TII
  • DTAA
  • Circulars (I-T Act, 1922)
  • Limited Treaties
  • Other Treaties
  • TIEAs
  • Notifications
  • Circulars
  • Relevant Sections of I-T Rules,1962
  • Instructions
  • Administrative Orders
  • DRP Panel
  • I-T Act, 1961
  • MLI
  • Relevant Portion of I-T Act,1922
  • GAAR
  • MAP
  • OECD Conventions
  • Draft Guidelines
  • DTC Bill
  • Committee Reports
  • FATCA
  • Intl-Taxation
  • Finance Acts
  • Manual on EoI
  • UN Model Taxation
  • Miscellaneous
  • Cost Inflation Index
  • Union Budget
  • Information Security Guidelines
  • APA Annual Report
  • APA Rules
  • Miscellaneous
  • Relevant Sections of Act
  • Instructions
  • Circulars
  • Notifications
  • Draft Notifications
  • Forms
  • TP Rules
  • APA FAQ
  • UN Manual on TP
  • Safe Harbour Rules
  • US Transfer Pricing
  • FEMA Act
  • Exchange Manual
  • Fema Notifications
  • Master Circulars
  • Press Notes
  • Rules
  • FDI Circulars
  • RBI Circulars
  • Reports
  • FDI Approved
  • RBI Other Notifications
  • FIPB Review
  • FEO Act
  • INTELLECTUAL PROPERTY
  • CBR Act
  • NBFC Report
  • Black Money Act
  • PMLA Instruction
  • PMLA Bill
  • FM Budget Speeches
  • Multimodal Transportation
  • Vienna Convention
  • EXIM Bank LoC
  • Manufacturing Policy
  • FTDR Act, 1992
  • White Paper on Black Money
  • Posting Policy
  • PMLA Cases
  • Transfer of Property
  • MCA Circular
  • Limitation Act
  • Type of Visa
  • SSAs
  • EPFO
  • Acts
  • FAQs
  • Rules
  • Guidelines
  • Tourist Visa
  • Notifications
  • Arbitration
  • Model Text
  • Agreements
  • Relevant Portion of I-T Act
  • I-T Rules, 1962
  • Circulars
  • MISC
  • Notification
  • About Us
  • Contact Us
  •  
     
    A Taxindiaonline Website. Copyright © 2010-2025 | Privacy Policy | Taxindiainternational.com Pvt. Ltd. OPC All rights reserved.