H25 - Business Taxes and Subsidies including sales and value-added (VAT)Návrat zpět

In accord with international transfer pricing regulations, the borrower's creditworthiness is the main factor to be reflected in valuation of cross-border loan transactions between associated enterprises. However, trouble invariably arises for small and medium-sized enterprises that do not have an assigned credit rating. The aim of this paper is to determine the most reliable predictors of a company's credit rating for European entities facing missing rating coverage for the purpose of transfer pricing. Based on 2015-2019 data sourced from the Orbis database, the study examines key financial ratios and non-financial information that could be instrumental in reconstructing a long-term rating category of a company assigned by Moody's Investors Service. The results identify interest coverage as the most useful predictor. Therefore, a law-approved and tax-acceptable approach to pricing of financial transactions between unrated parties (i.e., without credit rating) should preferably exploit interest coverage as a link to the otherwise missing ratings.

This paper examines various configurations of the formula under the formulary apportionment methodology from the perspective of the explanatory power of the variability in profitability of multinational companies with the aim to identify the best-performing formula based on analytical evidence of panel microeconomic data. The considered configurations of the formula are based on the novel composition of the allocation formula indicated under the BEFIT proposal, preceding the CCCTB proposal, and traditionally used formulas, at the sub-national level, in Canada and the United States. The empirical analysis uses microeconomic panel data obtained from the Orbis database for 77,087 subsidiaries affiliated with 2,283 parent companies observed from 2011 to 2020. Utilising the correlated random effect approach, accounting for time-specific effects, including the time-constant explanatory variables such as economic activity, classified by NACE codes and the EU Member States' jurisdiction, this paper devises a novel formula configuration. Besides a novel configuration of the apportionment formula, consisting of sales, costs of employees, tangible and intangible assets, this paper estimates proportional weights of apportionment factors and concludes with policy recommendations.

Irresponsible behaviour practices of tax entities are becoming more sophisticated. In addition to repressive tools, the tax administrator may use a proactive approach to detect an entity’s illegal activity. The paper aims to identify the relevant factors and assess their impact on estimating the probability of irresponsible behaviour of companies towards the tax administrator in individual sectors of the economy. Based on data from financial statements, we monitored the characteristic features of tax-responsible and tax-irresponsible companies in the Slovak Republic in the period 2015–2018 in 15 sec-tors. We created predictive models of their irresponsible behaviour towards the tax administrator for each industry using logistic regression. The results show that an analysis of the quantitative features of companies makes it possible to identify factors that alert the tax administrator in advance to potentially illegal behaviour of tax entities.

The aim of the paper was to propose a progressive corporate taxation in the Czech Republic and to evaluate whether the introduction of the progressive corporate taxation could straighten the position of Czech taxpayers in the view of the tax burden and equity of taxation. We designed and evaluated a sliding progressive taxation with 5 tax bands. Panel regression was also applied to estimate the taxpayers' response to changes in the statutory tax rate. According to the proposed progressive corporate taxation, micro-enterprises would face 13.59% of tax burden, small enterprises 17.40%, medium-sized enterprises 20.18% and large entities 22.42%. The results show that increased fairness of taxation and a decreased regressive effect of taxation would be reached through the progressive corporate taxation. However, due to the increased mobility of profits, it is assumed that the fairer position may be disrupted and the progressive corporate taxation itself would only increase the tax collection, stabilization function and tax distribution function as a result.

Theory supposes that corporate income taxation encourages companies to issue debt as opposed to equity finance because interests are deductible while dividends are not. In addition, international differences in tax regimes incentivize multinational firms to shift debt to optimize their taxes. Since a high debt level can have adverse consequences, we decided to find out whether taxation is one of the causes of indebtedness of the non-financial corporate sector. We used a macroeconomic approach, i.e., all the variables were constructed at the country level, and employed data for 17 EU member states for the period 2006–2014. The model for short-term indebtedness suggests that there is a relationship between corporate debt and taxation, especially between the debt-shifting incentive and the thin capitalization rule. However, the model for total indebtedness does not provide any evidence that corporate taxation influences the non-financial corporate sector debt. The firms’ debt was affected rather by macroeconomic factors.

The article discusses the issue of base erosion and profit shifting in relation to the Czech corporate income taxpayers. We describe the basic techniques how the base erosion and profit shifting can be realized and analyze the occurrence of the base erosion in the Czech Republic. We compare the average ROE and ROA ratios for the largest Czech entities with those achieved by the largest companies in Luxembourg, Netherlands, and Switzerland as the countries are generally considered as tax havens. Malta is also included in the analysis. The main hypothesis is the conjecture that the Czech companies' corporate income tax base is influenced by transactions with related parties mainly by using royalties and intragroup trades in goods and services i.e. through transfer pricing. As the Czech taxpayers, based on the results of analysis, achieved in 2006-2015 period lower ROE as well as ROA in comparison to the selected countries (with an exemption of Switzerland) it can be concluded that their tax base is likely influenced by aforementioned profit shifting techniques.

The non-existence of a link between reaching smart, sustainable and inclusive growth and the EU budget is resulting in the existence of sustainability gaps in the European Union. This research reveals that the introduction of the Common (Consolidated) Corporate Tax Base (hereinafter as C(C)CTB) could be an important contribution to close the existing sustainability gaps. To research the revenue potential of the C(C)CTB, a model based on a remittance system was designed. The system expects the replacement of the VAT-based own resource (resp. GNI-based own resource) through the transfer of a part of the corporate tax revenues from the C(C)CTB raised on the national level to the EU budget. The results of the research show that the C(C)CTB-based own resource would be able to fully replace the VAT-based own resource, with the only exception of Cyprus. However, the C(C)CTB-based own resource cannot be considered to be a sufficient resource to fully replace the GNI-base own resource.

We contribute to the rare evidence of driving motives of establishing new onshore and offshore companies by analysing the situation in the Slovak Republic in 2014. We analyse financial and ownership data for the Slovak enterprises already included in onshore and offshore business, providing data by corporate service providers on the driving motives and their combination for the Slovak customers in 2014 and the available external data assessing the quality of the Slovak business environment. We present the empirical evidence that the motive of tax benefits is ranked as the most important, followed by the anonymity of the UBO, flexible arrangement of ownership relations, asset protection, asset management and trusteeship and special cases. In the second part of our research we provide empirical evidence on significant areas of the business environment affecting the number of newly established onshore and offshore companies by the Slovak enterprises between 2005 and 2014. The indicators assessing the quality of the Slovak business environment are divided into two groups - paying taxes plus doing business and the quality of the legal system in Slovakia. Our research shows that from the first group is insignificant only the indicator of time to comply with taxes. On the other side, the perception of corruption and the functionality of the state institutions are evaluated as significant from the second group.

Investors' decisions are not based only on the statutory tax rate in the country, but also on a range of other aspects, such as depreciation of fixed assets, treatment of foreign source income, property taxes paid by firms, as well as treatment of dividends paid by companies and taxes on wealth and capital gains at the level of individuals. These aspects are incorporated into the model created by the Centre for European Economic Research (ZEW). This model provides a comprehensive look at the issue of tax competition, therefore the paper deals with describing and explaining its construction. The benefit is description of the effective average tax rate (EATR) in the Slovak conditions, evaluation of its development and changes by the different types of assets and the ways of financing, as well as forecasting its level based on the change in the corporate income tax rate. The indicator, which represents the level of capital taxation, is complicated to determine. EATR means the significant progress on this issue.

The worldwide adoption of the International Financial Reporting Standards (IFRS) has not affected financial reporting only, but it has also impact on taxation systems. Countries with a high level of book-tax conformity (dependence) have to solve whether and at what extent to allow IFRS results for the corporate taxation. The paper deals with the specifics of Czech Republic, which is an example of open small economy with relatively high subordination of accounting to taxation purposes. To allow IFRS in tax fillings of those entities preparing statutory financial statements in compliance with IFRS may thus represent a comparative advantage for Czech economy. We hypothesize that usage of IFRS for tax purposes is "win-win-win" situation, as it may (1) significantly decrease the compliance tax costs of IFRS entities; (2) increase the capability of tax authorities to supervise the fulfilment of tax duties by IFRS entities; (3) create a favourable tax regime attracting foreign companies to tax their sources of income in the Czech Republic/mitigating the motives of Czech companies to transfer profits abroad. We support our findings by the analysis of micro- and esp. aggregate tax data showing that (a) taxation rules have a greater influence on tax base than accounting profits (b) changes in reported accounting profits are a function of business cycle rather than a function of changing tax rates and/or a function of accounting method choices.

The implementation of the Common Consolidated Corporate Tax Base (hereinafter as CCCTB) system will have the impact on the distribution of group tax bases across the EU, for the draft of CCCTB directive includes also the suggestion of allocation formula, based on which the group tax base should be allocated. As a consequence of this, it will also generate impact on tax revenues of individual EU Member States. The aim of the paper is to identify whether the implementation of CCCTB will result into the decrease or increase of corporate tax base in the Czech Republic in comparison with present situation - i.e. in situation when no group taxation or consolidation regimes are allowed in the Czech Republic. The results shows that Czech Republic would gain in the situation when CCCTB would be implemented in EU28, for its total allocated tax base would increase by 11,61%.

The empirical literature generally accepts the influence of corporate taxes on the investment decision of the multinationalities. The most papers usually consider more aspect of that tax then only statutory corporate tax rate. Using annual time series data for the period 1998-2011 this paper examines the influence of EMTR and EATR including their components on the foreign direct investments in the EU Member states. The main aim of the paper is to evaluate which of the selected types of effective tax rates explains the investment decisions of the multinationalities the best. The results show that the commonly used indicators of effective tax burden are not the best option for foreign direct investment (FDI) explanation in the investigated model. Perhaps the best indicator for evaluating dependencies between explanatory variables and FDI are the average and marginal effective tax rate from industrial buildings.

There are currently held tough discussions among economists and policy makers on the most appropriate form of taxation that would be fair, simple, enough incentive to wage work and entrepreneurship and withal also providing sufficient revenue for the state to fund the services provided to citizens. In this debate two opposing views on the basic form of this system stand against each other, namely, whether it should tax the income in a progressive manner, as is the case with tax systems applied today in most countries, or in a proportional manner, which has been introduced in a limited extent in several countries, especially in Central and Eastern Europe. This article provides a brief description of the basic characteristics of both these approaches and summarizes the main arguments presented by their proponents and opponents. The next section describes the different variants of a proportional system, also known as a flat tax system, some of which currently exist only in the yet unrealized proposals, and in the end, then compare their pros and cons.

The policy of investment incentives is applied in majority of countries all over the world. This popularity is in contradiction with rare academic analyses. This paper sheds some light on causal impact of such policy on investment of supported firms in Czech Republic. We use individual level panel data containing crucial observables about the firm behaviour. We overcome the selection problem by application of propensity score matching. Our comparison of investment behaviour of supported firms and firms from control group shows that the extra investment generated (or maybe only accelerated) was at most 26% of contracted amounts. Even with constraints and assumptions we explicitly discuss in our work, this indicates that the arguments for the provision of this policy in Czech economy are not valid. These findings are in line with mixed (but mostly similar) empirical evidence from other countries.

The paper focuses on accrual taxes, investment and depreciation in government sector from statistical point of view. The paper is a feedback on paper published in Politická ekonomie 2/2010 by authors Hrdlička, Ištvánfyová and Vítek. Original paper dealt with similar issue but from accountants' point of view. The statistical view of this matter is slightly different and it is influenced by current national accounts' standard ESA 1995. The most of the paper is devoted to the investment and depreciation, in national accounts terms capital formation and capital consumption. The sector of government is a very important investor and property owner in the Czech Republic. Therefore a good record of investment and depreciation is important not only for government sector itself but also for total economy.

The purpose of this paper is to run a panel regression analyzing the impact of economic, legislative and social factors on corporate tax revenues, as defined by existing empirical and theoretical literature. Literature which directly addresses factors influencing corporate income tax revenues is quite limited - in respect of number of papers as well as in respect of the range of examined countries and/or time period. The latest and key papers include among others Clausing (2007), Devereux (2006) and partly Kenny, Winer (2006) and Gropp, Kostial (2000). Presented article on the other hand covers observations for all OECD countries for a rather long time period 1980-2006. The authors believe that this paper addresses all important factors having influence on corporate income tax revenues, including tax avoidance and debt financing. The results of the analysis largely correspond to existing investigations of other authors; however, presented regression is of more complex and general character - it includes other factors of tax avoidance and data for all OECD members (except for some variables which are not available), including post-communist countries.

The Czech Republic has introduced new energy taxation in connection with implementation of the directive 2003/96/EC, restructuring the Community framework for the taxation of energy products and electricity. New energy taxes are imposed on electricity, solid fuels and natural gas, with term of initiation on 1st January 2008. This paper discusses impact of new energy taxation on sectors NACE in the Czech Republic, particularly on prices of production. I have created the simple short-term price model for the Czech Republic, which is based on input-output methodology by Leontief. The paper is divided into six parts. The first part is introduction, where are formulated both the main target of the paper and two hypotheses for testing. The theoretical problems, which are connected with the impact of taxation and tax incidence, are discussed in the second part. The third part describes possibilities of analysing and modelling in the area of changes of tax system and tax rates. In the fourth part I describe the methodology and then I am creating the short-term price model for the Czech Republic. The next part consists of the main results, emerged from the price model and the two hypothesis testing, with focus on energy intensive sectors of NACE. The last part, conclusion, summarizes the main results and formulates the possibilities of additional research in energy taxation area.

The Czech tax system is undergoing radical transformation. Among the many forthcoming changes, several features can be identified, which alter the structure of tax asymmetries. This paper uses an option-based model of direct taxation to examine a controversial new thin-capitalization rule, stipulating a mandatory benchmark for deductible unrelated-party loan expenses. We estimate the costs of debt under various risk-related scenarios, focusing on particular situations where the new regulation may result in distortions of business incentives and investment behaviour. We find that the measure can disproportionally increase the marginal cost of debt for companies with relatively risky business profiles. In particular, if the law were followed strictly, it could create effective barriers to further growth under perfectly realistic combinations of leverage and business risk. Another asymmetry arises due to a small-business exemption which can make new investment prohibitive when its cap is being reached. The model also suggests that non-deductibility of interest increases credit risk and could, in the longer term, contribute to a slack in SME lending.