F23 - Multinational Firms; International BusinessReturn

The article presents the system of indicators for evaluation of taxation of international companies active in the Czech Republic. Based on the identification of the potential channels of corporate tax base erosion and profit shifting of multinational enterprises it enables to recognize companies whose taxation policy might not be in line with the best practice. Extreme values of the indicators might initiate further examination of a company by state authorities. This research thus complements the existing set of analytical tools of the government agencies and research institutions in the area of taxation of multinational enterprises.

The globalization of the economy during the last two decades was characterised by the growth of international trade volume and changed the pattern of its territorial structure. This development has been supported by the increasing role of global supply chains, by the implementation of modern IT technologies and was reflected in trade finance. The shift from traditional banking instruments to open account trade was in the long term obvious. The economic environment of the last financial and economic crises brought the necessity of more effective cash management, payment risk mitigation and reduction of operating costs. The BPO represents a resilient instrument based on electronic data exchange which can address the trade finance needs of both traders and financial institutions.

Foreign direct investments are generally considered as one of the factors with positive influence on the economic development of countries in which this investments flow. In evaluating the impact of foreign direct investment on development, however, a key question is whether foreign direct investment crowd in domestic investment, or foreign direct investment crowd out domestic investment. The aim of this paper is to examine whether foreign direct investment in selected countries of Balkan crowds in or crowds out domestic investment. For this purpose we apply theoretical model of investment that includes foreign direct investment as an exogenous variable. We proceed test it with panel data for the period 1993 - 2009 and the two subperiods 1993 - 1999 and 2000 - 2009. We found that for the time period 1993 - 2009 and the two subperiods 1993 - 1999 and 2000 - 2009 there was an evidence of crowding out effect or neutral effect in the selected countries of Balkan.

We review some relevant literature in the field of tax evasion avoidance proposals. Unfortunately legislative a political conditions (double taxation treaties, tax competition) prevent some of the most useful designs proposed in the scholar literature, to be widely used in Europe. Then we concentrated on properties of transfer pricing rules proposed by OECD guidelines - Cost+ method, comparable resale price method (CRP), profit split method (PSM), comparable uncontrolled price method. We used neoclassical microeconomic model of firm a simulation tools (random cost a income functions). We found that some of these methods (PSM, CRP with fixed discount) cause quite large distortions in the optimal quantity of final good (a therefore also intermediate product) produced. PSM also falls short on the instability of profitability between related industries in time. The most inconvenient property of Cost+ a CRP, which do not distort quantity produced by MNE if percentage markup (discount) is used, is that they are very sensitive to quality of database revenue authority uses, to stability of prices within industry a to profit margin. VAT or turnover taxes are naturally less sensitive, so emphasis on VAT might be a partial solution of multinationals' pricing problem.