Zur Zeitwertbilanzierung latenter Steuern in der internationalen Rechnungslegung

The significance of deferred taxes was increased by the introduction of international financial reporting standards. However, the usefulness of the information provided by interperiod tax allocation is regarded with skepticism by researchers and practitioners alike. This is largely due to the overestimation of the book value of non-current deferred tax liabilities and deferred tax assets as the present value of these items is disregarded. The IASB refuses to discount deferred taxes even though this would comply with the underlying asset-liability-concept. The IASB justifies the ban on discounting deferred taxes by the ??supposed?? high complexity; hence, cost-benefit considerations. The paper at hand analyses critical issues regarding the determination of the present value of deferred taxes. An approach for determining the maturity of deferred taxes, a risk-adequate discount rate and an approach for the derivation of a feasible net present value calculation are proposed. It is shown that discounting of deferred taxes is generally possible without resulting in more complex estimations than in those of other accounting areas. Despite the inevitable discretion management has in estimating the present value, it is still possible to represent such information faithfully so that the relevant information is useful to external users.     

Latente Steuern und Earnings Management

On the one hand deferred income taxes can be used for earnings management for external reporting purposes by itself. On the other hand deferred income taxes can indicate earnings management in other accounting areas, fraud and aggressive tax management. Empirical research was able to identify the usefulness of information provided by sundry components of the reported income tax expense for users of financial statements. In particular, the German literature concerning financial statement analysis underestimates the value of this information. This paper critically reviews empirical research and draws conclusions for financial statement analysis and for future studies in this area.     

Die Abgeltungsteuer auf Kursgewinne und der Steuerstundungseffekt in der Unternehmensbewertung

In Germany capital gains have to be taxed independently of the holding period, according to the withholding tax regulations. Nevertheless, investors can initially avoid taxation by not realizing capital gains. Then, taxes are postponed into the future. Thereby investors can make use of an interest-free tax loan (tax deferral). Equally beneficial would be the immediate realization of negative capital gains, if this leads to reduced taxes by balancing these losses against other gains. The potential use of interest-free tax loans leads to the necessity of making assumptions on the investors?? strategy with respect to liquidation when it comes to business valuation based on discounting future after-tax payments towards investors (DCF-methods). It will be shown how much firm value depends on these assumptions by taking alternative, inflexible and flexible strategies of investors into account. Our considerations generate a lower and an upper bound for the firm value, and easier to calculate medium values. The calculations are illustrated by a numerical example which is also the subject of a comparative static analysis.     

Auswirkungen der deutschen Unternehmensteuerreform 2008 und der österreichischen Gruppenbesteuerung auf den grenzüberschreitenden Unternehmenserwerb

Using a simple model under certainty we show the implications of the new group relief system in Austria effective from 2005 and the reform act of business taxation 2008 in Germany on cross border marginal purchase prices and marginal seller prices concerning incorporations. The results show that the new group relief in Austria does not imply a higher marginal purchase price for a subsidiary located in Austria by an Austrian investor in comparison to his German competitor. If the German reform act of business taxation 2008 is not taken into account a German investor is able to pay higher marginal prices at the Austrian and German transaction market for companies. Considering the German tax reform act the situation changes. Now the Austrian investor is able to pay higher marginal prices for subsidiaries located in Germany and Austria.     

开放经济中跨国公司的最优所得税模型

通过对不同避免双重征税方法下最优所得税模型的建立,解析了政府最优政策的收入函数,得到税收竞争均衡中的公司所得课税政策.对小型开放经济而言,在扣除法和抵免法,以及免税法与抵免法的不对称体系下,对跨国公司从源征收公司所得税都是最优选择.由此,得到不同于国际税收经典理论的结论.     

Taxes and the choice between risky and risk-free debt: on the neutrality of credit default taxation

Shareholders can decide if their corporation issues risky or risk-free debt. We identify tax systems in which the choice between risky and risk-free debt is not distorted by taxes. These credit default neutral tax systems make it possible to make capital structure decisions and firm valuations neglecting credit default risk, even after taxes. Thus credit default neutrality is a characteristic of a tax system that helps to reduce planning costs. Moreover, credit default neutrality is a necessary condition for financial neutrality of taxation. We find one class of credit default neutral taxes that preserves and another class that modifies the expected tax distribution between creditors and debtor firm. Finally, we show the influence of personal taxation on credit default neutrality.

Tax attractiveness and the location of German-controlled subsidiaries

This paper analyzes whether taxation has an influence on the location decisions of multinational enterprises. We employ a novel set of 22 tax variables, such as the taxation of dividends and capital gains, withholding taxes, the existence of a group taxation regime, and thin capitalization rules. Furthermore, we use the Tax Attractiveness Index, a new aggregate measure containing the 22 tax variables. Our count data regression analysis is based on a novel hand-collected dataset consisting of the subsidiaries of German DAX30 companies in 97 countries. Controlling for non-tax effects, we find that a country’s tax environment has a significantly positive effect on the number of German-controlled subsidiaries and, therefore, on the location decisions of German multinational enterprises. Specifically, our analysis reveals that German multinational firms place affiliates in countries that offer favorable statutory tax rates, withholding taxes, double tax treaty networks, and holding incentives. Additionally, we find that the Tax Attractiveness Index has explanatory power in subsidiary location decisions and, therefore, it can be used as alternative composite measure, for example, when 22 single tax variables are not at disposal.     

Modellierung von Aktienanlagen bei laufenden Umschichtungen und einer Besteuerung von Veräußerungsgewinnen

This paper develops a technique which simplifies the calculation of terminal values of share investments when portfolio turnovers repeatedly trigger capital gains taxation. So far, the calculations of these values are difficult, due to recursive dependencies, which cannot be expressed by geometric series. Using our technique, tax burdens of differently taxed forms of share investments can be determined in an easy way even if these methods imply different elements of deferred taxation (equity funds, certificates, preferred taxed pension plans). The simplification is reached by assuming a specific trading strategy. This strategy is in line with empirically observed investor behavior which is characterized by periodical portfolio turnovers and reluctance to realize taxable capital gains.     

Environmental Taxes and the Choice of Green Technology

We study several important aspects of using environmental taxes to motivate the choice of innovative and “green" emissions‐reducing technologies as well as the role of fixed cost subsidies and consumer rebates in this process. In our model, a profit‐maximizing monopolistic firm facing price‐dependent demand selects emissions control technology, production quantity, and price in response to the tax, subsidy, and rebate levels set by the regulator. The available technologies vary in environmental efficiency as well as in the fixed and variable costs. Both the optimal policy for the firm and the social‐welfare maximizing policy for the regulator are analyzed. We find that the firm's reaction to an increase in taxes may be non‐monotone: while an initial increase in taxes may motivate a switch to a greener technology, further tax increases may motivate a reverse switch. For the regulator, we compare the social welfare achievable in the centralized system (which serves as an upper bound) to the highest level achievable under different classes of environmental policies. If the regulator is limited to a tax‐only policy, then when the regulator is moderately concerned with environmental impacts, the tax level that maximizes social welfare simultaneously motivates the choice of clean technology and closes the gap to the upper bound; however, both low and high levels of societal environmental concerns may lead to the choice of dirty technology and significant welfare losses as compared to the centralized case. Supplementing the environmental taxation with fixed cost subsidies and consumer rebates can eliminate this effect, expanding the range of parameters over which the green technology is chosen and often closing the welfare gap to the centralized solution.     

The impact of tax uncertainty on irreversible investment

Traditional models of capital budgeting with taxes are based on deterministic tax rates and tax bases. In reality, however, there are multiple sources of tax uncertainty. Frequent tax reforms make future taxation of investments a stochastic process. Fiscal authorities and tax courts create additional tax uncertainty by interpreting current tax laws differently. Moreover, simplified models that anticipate the actual tax base incorrectly contribute to tax uncertainty as perceived by investors. I analyze the effects of stochastic taxation on investment behavior in a real options model. The investor holds an option to invest in an irreversible project with stochastic cash flows and stochastic tax payments. Pre-tax cash flows and tax payments are assumed to be correlated. Increased tax uncertainty has an ambiguous impact on investment timing. For low tax uncertainty, high cash flow uncertainty and high correlation of cash flows and tax payments, increased tax uncertainty is likely to accelerate investment. A higher expected tax payment delays investment. A higher after-tax discount rate affects investment timing ambiguously.     

The determinants of opting for the German group taxation regime with regard to taxes on corporate profits

Forming a tax group for corporate and trade tax purposes in Germany has its advantages in terms of tax savings for the companies concerned. Depending on the profit situation, for certain companies these benefits were extended by the 2001 German corporate tax reform. However, setting up a tax group in Germany is also accompanied by certain disadvantages for the consolidated companies, resulting especially from the assumption of increased liability for subsidiaries’ losses. The objective of this study is to investigate the factors determining the decision in favour of, or against, the formation of a tax group. A natural experiment arising from the 2001 German corporate tax reform allowed us to determine to what extent companies exploited the increased potential benefits of a tax group post reform. We test this finding employing firm-level data from the database AMADEUS. Our results show that the number of tax groups increased significantly with the introduction of the exemption method as from 01.01.2001. This result is especially apparent amongst companies benefiting from a tax group only post reform. Yet eligible companies which would have obtained tax benefits by entering into a tax group did not always choose this option. This applies in particular to parent companies with subsidiaries that are not wholly owned, and to small subsidiaries.     

Die Bedeutung von Steuern in der Nachhaltigkeitsberichterstattung: Eine international vergleichende empirische Analyse

Due to tax competition, high levels of national debt and promulgated tax avoidance strategies of large corporations, there is a growing interest of multiple stakeholders in taxation putting taxes on the corporate social responsibility (CSR) agenda. This study empirically examines the relevance of taxes in sustainability reports of 90 corporations listed on the Dow Jones 30, DAX 30 and FTSE 100. The findings show that 54,4?% of these corporations disclose tax information in their reports. The quality of disclosure is examined using a scoring model based on the tax-related performance indicators of theGlobal Reporting Initiative Guidelines and two standards for voluntary disclosure of tax information. In most cases, disclosure practices are of low quality. However, there are a few corporations providing high disclosure quality, especially in the UK. By analyzing the determinants of disclosure, this study demonstrates that extractive companies and companies that have been object of negative tax-related media coverage tend to disclose more information. Furthermore, corporations with higher profitability and high performance in CSR rankings rather disclose tax information.     

Taxes,risky investments,and the simultaneous choice of organizational form and financing

By taking explicit account of liability limitations, we analyse the influence of taxes on the simultaneous choice of organizational form and financing. In a two-state model for a single reporting period investors striving for maximisation of expected utility choose the organizational form (with or without liability limitation) in which they implement a given risky real investment and decide how they finance it (equity or debt). We demonstrate that liability limitations result in tax-relevant differences between organizational forms. Thus, for example, the tax bases differ in relation to the chosen liability-contingent debt capital compensations as well as to tax loss offset rules. Therefore, even in the event of identical tax rates, taxes can influence the decision regarding the organizational form.     

Die Entscheidung über den Verkauf von Wertpapieren unter der Abgeltungssteuer und auf Basis subjektiver Erwartungen

Since January 1, 2009 realized capital gains on securities are taxable in Germany regardless of the investor’s holding period. This paper examines when a rational investor should optimally sell a security in the presence of capital gains taxes. Besides taxes, our analysis considers the relevance of investor’s subjective expectations about future market prices of the security. The results suggest that investors should base divestment decisions primarily on their expectations. To realize losses or to avoid the realization of taxable gains (i.e. the lock-in-effect) is of minor importance for the optimal divestment strategy. This result becomes even more pronounced when transaction costs and limitations to save taxes by realizing losses are considered. Numerical calculations illustrate the results of our analysis.     

政府补贴、成长性和亏损公司定价

本文以Ohlson模型考察2002-2007年A股亏损公司定价问题。针对亏损公司盈余与权益价值负相关这一异常现象,我们通过将政府补贴、成长性、研发支出和负债融资信息引入定价模型,发现政府补贴、成长性和负债因素能够有效改善模型,消除了盈余与权益价值显著负相关的异常现象,改善了定价模型的效果。通过从规模和净利润两个维度对亏损公司的进一步分类,我们发现从净利润维度来看,政府向那些更容易通过非经常项目扭亏的公司提供了更多财政补贴,并且政府补贴与净利润为正公司的权益价值显著负相关,与净利润为负公司的权益价值不存在显著相关关系;从规模维度来看,上述现象在小公司样本更加明显。     

Financial Ownership,Diversification and Firm Profitability in Japan

The Japanese system of corporate governance andin particular the role played by banks andother financial institutions have been thesubject of considerable research andcontroversy in recent years. We estimate theimpact of equity ownership by financialinstitutions on firm performance in Japan for1986–1991, a period that precedes many of theproblems of the ensuing decade. We find thatwhile ownership by financial institutions isassociated with unprofitable diversification,such ownership is, on balance, positivelyassociated with firm profitability. Someimplications of these findings for Japan'sunique system of governance are discussed.     

燃油税、融资约束与企业行为——基于DSGE模型的分析

征收燃油税在实现节能减排的同时也会增加企业的财务负担。如何在保护环境的同时减少对经济的冲击,有赖于对燃油税的科学评估。本文构建了一个包含燃油税和融资约束的随机动态一般均衡模型,并基于1995年第1季度至2018年第2季度的数据对相关参数进行了校准和估计,系统考察了融资约束下征收燃油税对环境经济以及企业行为的影响。研究结果发现：征收燃油税对促进节能减排有显著效果;但同时也会抑制消费、投资和产出,增加失业,对经济产生负影响。此外,融资约束会通过金融加速器的作用放大燃油税冲击的影响。而且,当融资约束越强时,降低燃油税对经济的刺激作用也越明显。     

股权结构的适度性与公司治理效率

股权结构与公司治理效率存在着密切的关系,在一定条件下,股权结构决定着公司治理结构,适度的股权结构又是影响公司治理效率的决定因素之一。本文从股权结构的适度性角度来考察德美日公司的治理效率,并在此基础上提出了建立有效的公司治理的股权结构适度性模型,从而对转轨时期的中国企业公司治理改革具有一定的参考价值。     

Der Einfluss der Zinsschranke auf unternehmerische Kapitalstrukturentscheidungen

In principle corporations are free to raise debt capital or equity capital. To protect tax revenues and to increase corporations?? equity ratio Germany has introduced an interest ceiling rule. From a tax planer??s point of view it is not clear whether debt or equity capital is advantageous. On the basis of Miller (J Finance 32:261?C275, 1977) we analyze whether this interest ceiling rule discriminates debt capital against equity capital. We find that investors can be indifferent towards the capital structure with and without considering the interest ceiling rule. This result does not depend on the investors?? percentage of participation or the corporation??s optimal dividend policy. The result depends significantly on the profit, the deductible fraction of EBITDA, the tax rates and when capital gains are realized. The advantage of debt capital normally decreases due to the introduction of this regulation but in some cases even increases. Nevertheless, many investors will prefer debt capital even when the interest ceiling rule applies. This result also arises in the case of external debt financing. Thus, it is an open question whether this regulation leads to higher equity ratios.     

Warum Steuermoral? – Zur Explikation,Relevanz und Vorteilhaftigkeit von Steuermoral

The subject of this article is the explication, investigation of the relevance and the analysis of the advantages of tax morale. Tax morale is defined as the rejection of tax evasion and also as the rejection of special tax avoidance strategies. One argument in favor for tax morale is that tax payment can be interpreted as an elementary component of a fictitious social contract. In accordance with deontology ethics it can be traced back to the maxim “pacta sunt servanda”. Tax morale is relevant because tax evasion and tax avoidance strategies cannot be fully prevented by the tax law. The implementation of a social contract therefore requires a regulation for tax payment. The realization of a tax payment regulation would be simplified if tax payment would be beneficial. If economic income is accepted as an approximation of the financial utility from the social contract, the tax payment is absolutely beneficial in principle. In relation to the (immoral) non-payment of taxes, tax payment can be relatively advantageous or disadvantageous. One possible advantage is that (immoral) non-payment of taxes can result in punishment when detected. Another result of tax payment is the prevention of an impairment of the social contract.