H32 - Fiscal Policies and Behavior of Economic Agents: FirmNávrat zpět

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.

In this paper, estimates of tax losses as a result of aggressive tax planning are presented using two different methodological approaches. While the International Monetary Fund (IMF) methodology addresses profit shifting and corresponding tax losses across the European Union, the United Nations Conference on Trade and Development (UNCTAD) methodology uses FDI data and a list of so-called offshore financial centres. According to the IMF methodology, the annual tax losses are about EUR 69-105 billion for the EU-28. According to our calculations, the Czech Republic achieves negative losses (tax revenues) of CZK 15 billion per year, probably due to the low effective tax rate (16.4%) and investment incentives. On the other hand, the UNCTAD methodology implies annual tax losses for a given EU member state of about EUR 18 billion. Because of limited data availability, we estimated the regression model for only 22 EU member states for the period 2013-2016.

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.

Corporate Sector-Selected Aspects of Empirical Analysis of the EU Member States The paper attempts to shed light on selected problems of mainly non-fi nancial corporations of EU Member States in the period 1995-2013 (2014) using financial balance sheets (SNA, 2008). The relations between domestic sectors and non-residents have revealed that the Member States have been mainly debtors during the examined period. Having measured leverage (ratio of debt to GDP created in the sector of non-financial corporations) we have found out the increase of the ratio in the crisis period (2008-2013) in the sample of 17 member states. As concerns the ratio of debt to shares we have stressed the heterogeneity in the sample of 8 eurozone countries. The heterogeneity has been discovered also examining the role of trade credit as an alternative source of financing in the random effects model (panel analysis).

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.

The paper focuses on selective investment incentives, which are aimed primarily to attract foreign direct investment, in the context of the new EU Member States, namely the Czech Republic, Hungary, Poland and Slovakia. We discuss the issue within three closely related dimensions. We point to a potential conflict of interests between host country governments and multinational companies in promoting technology spillovers from foreign direct investment in the host economies. We examine the prisoner dilemma of the host governments in mutual competition for mobile direct investment and a room to achieve multilateral or strengthening regional agreement on investment to reduce a possible wealth reducing content of such policies. Finally, we discuss national context of the investment incentives with regards to the rent-seeking behaviour of various interest groups and contradictory role of the investment promotion agency in the process of decision-making about investment promotion policies. We conclude with brief implications for development policy.