The Direct and Indirect Costs of Tax Treaty Policy : Evidence from Ukraine

Balabushko, Oleksii ; Beer, Sebastian ; Loeprick, Jan ; Vallada, Felipe

World Bank, Washington, DC

关键词: tax treaty;    transfer pricing;    domestic resource mobilization;    fiscal policy;    revenue collection;   

DOI  :  10.1596/1813-9450-7982
RP-ID  :  WPS7982

学科分类：社会科学、人文和艺术（综合）

来源: World Bank Open Knowledge Repository

【 摘 要 】

This study combines macro and micro datato quantify the revenue effects of double tax treaties.First, drawing on administrative information, the studyestimates the tax sensitivity of income flows (dividend,interest, and royalty payments) at an aggregate level. Theanalysis finds important direct revenue costs linked totreaty restrictions on taxing rights, especially for flowsinto a few major investment hubs. However, high elasticitiesof income flows also suggest that increases in withholdingrates at the individual treaty partner level would notnecessarily result in more revenue collection. Second, thestudy uses firm-level information to estimate thesensitivity of reported profitability to changes in therelevant treaty network. The analysis of the reportedearnings of multinational enterprise affiliates in Ukrainesuggests that the ownership structure and operations withaffiliates in certain jurisdictions explain reportedprofitability, and should thus receive increased attentionin risk assessment and transfer pricing audit activities.