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EN
All MNEs generate their revenues through a business model which have a certain organization of functions performed, assets used and risks assumed. Nevertheless, the changes in economic environment have resulted into the situation, when all governments have been increasingly focused on raising revenues through taxation and conversely many MNEs have been focused on decreasing of their taxable business income with using various means. One possibility how to achieve it for both sides is a transfer pricing. The aim of the paper is to create a general model, under which the MNEs could decide for the best business model within the frame of the tax planning, but which would also enable to quantify the impacts on the state budget resulting from that tax planning strategy. Furthermore, the general model determinates more accurate arm's length transfer prices in the business model with respect to recommendations in OECD TP Guidelines, particularly functional and comparability analysis.
EN
This paper evaluates the impact of the European Commission’s Proposal for a Council directive on the Common Consolidated Corporate Tax Base (CCCTB) (COM (2011) 121/4). We analyse the impact of the apportionment formula to be applied to the CCCTB on the revenues of the Slovak state budget. The sample of our analysis is composed of eleven transnational corporations operating in the Slovak Republic and other EU member states. The results indicate a decrease in tax revenues under the proposed CCCTB system in comparison to the current national tax legislation. By contrast, according to the data available, the likelihood that Slovakia will benefit from the CCCTB system by collecting more taxes seems to be low.
EN
This study aims to investigate the effectiveness of fiscal rules in terms of government expenditure and tax revenues with and without the threshold effect of the budget deficit over the period 1995 – 2019 in 91 emerging European countries, as the frequency and severity of the implementation of fiscal rules vary according to the level of the budget deficit. To achieve this objective, the study firstly examines this relationship using the fixed and random effect methods without considering the threshold effect of budget deficit. Secondly, the study employs the panel threshold method proposed by Hansen (1999) to examine this relationship with the threshold effect of budget deficit, which is different from previous studies. Based on the panel threshold estimation, the results reveal that there are two threshold levels of budget deficit on government expenditure and a single threshold level of budget deficit on government tax revenue. Depending on these thresholds, the effect of fiscal rules on government expenditure and tax revenue varies significantly. This suggests that fiscal rules are more effective in ensuring fiscal discipline when the budget deficit is high and less effective when the budget deficit is low.
EN
Common Consolidated Corporate Tax Base (hereinafter as CCCTB) system can be introduced under enhanced cooperation or as optional in EU, thus countries not implementing the system can face the outflow of tax bases into jurisdictions applying CCCTB system, which will have the impact on EU Member States budgets. The aim of the paper is to quantify the outflow/inflow of the tax bases from/in to the Czech Republic as a result of the implementation of the CCCTB system in EU-27 and to quantify the impact on the corporate tax income revenue. The research performed in the paper revealed that the optimal implementation of CCCTB system in EU-27 except of the Czech Republic would negatively change the corporate tax base, as the loss would range between 0.77% and 6.77% of the current tax base, which represents 0.20% to 1.73% of current corporate tax revenues. Moreover, the Czech Republic can also face outflow of tax bases of the parent companies.
EN
Within the EU, the Czech Republic belongs to the countries with unemployment below average. Therefore, it may seem that unemployment benefits and other direct costs connected with unemployment constitute a rather small expenditure. In our paper we show that this first impression is false. This paper comprehensively assesses the impact of unemployment on the public budgets. Its contributions are as follows: (1) we discuss the methodological problems that are associated with particular methods of the impact calculation, and (2) we quantify the impacts for the Czech Republic budgets in the years 2010 – 2015 and compare them with other studies. Our results suggest that in 2015 the annual costs of unemployment reached EUR 9.064 per unemployed person. According to other studies, the nominal value of the costs is slightly higher than is the case in Slovakia (as a similar economy) and lower than the results for traditional European countries. The results are also lower when the costs are compared to average labour costs in the economy.
EN
European Commission re-launches the common consolidated corporate tax base (CCCTB) in Europe within the efforts to fight with tax evasion and tax fraud via two step procedure. Firstly, only a common corporate tax base (CCTB) would be implemented with the possibility of cross-border loss offsetting CCCTB. Common consolidated corporate tax base should be introduced only in the second step. The aim of the paper is to research the impact of both implementation steps on the amount of the tax bases allocated in the Slovak Republic. The results show, that the first implementation step would results into the decrease of allocated tax bases by 0.27% in the Slovak Republic. The second implementation step would result in to the increase of the tax bases allocated in the Slovak Republic by 3.02%.
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