Supply Chain Strategies and International Tax Arbitrage

What motivates the geographic footprint of the supply chains that multinational firms (MNFs) deploy? Traditional research in the operations and supply chain management literature tends to recommend locations primarily based on differentials in production costs and the ramifications of physical distance ignoring the role of taxation. MNFs that strategically position parts of their supply chains in low‐tax locations can allocate the profits across the divisions to improve post‐tax profits. For the profit allocation to be defensible to tax authorities, the divisional operations must possess real decision authority and bear meaningful risks. Generally speaking, the greater the transfer of risk and control, the larger the allowable allocation of profit. These transfers may also create inefficiencies due to misalignment of business goals and attitudes toward risk. We model these trade‐offs in the context of placing in a low‐tax region a subsidiary that oversees product distribution (as a limited risk distributor commissionnaire, limited risk distributor, or fully fledged distributor). Our analysis demonstrates that the MNF's preferences regarding the operating structures are not necessarily an obvious ordering based on the amount of risk and decision authority transferred to the division in the low‐tax jurisdiction. We derive and analyze threshold values of the performance parameters that describe the main trade‐offs involved in selecting an operating structure. We find some of the optimal decisions to exhibit interesting non‐monotone behavior. For instance, profits can increase when the tax rate in the low‐tax jurisdiction increases. Numerical analysis shows that the Limited‐Risk Distributor structure is rarely optimal and quantifies when each alternative dominates it.     

Public planners and business investors—Why can't they collaborate?

Effective long-range investment plans covering international asset management will take into account not only the business environment but external factors, especially political and regulatory uncertainties, which can dampen profits and cash flows anticipated over the economic life of the projected investment. Although financial concession packages promoted by development agencies tend to compensate for some of these costs arising from uncertainties, this approach to industrial development is fraught with obstacles. A closer examination of one such program reveals why concessioned firms are leaving or failing, despite numerous advantages, and why the developement agency may be unable to offset future adverse trends.     

Income Shifting in Italian Business Groups and some Governance Implications

This paper explores the relationship among group control, financial reporting strategies and governance implications in the pursuit of domestic tax planning. A very large number of papers deals with international tax planning in multidivisional enterprises, but very few are devoted to exploring significant incentives for national business groups to engage in tax planning strategies. In this paper we propose a one-period model relating to the tax incentives of income shifting in Italian business groups. We show that, given the total amount of expected earnings before taxes and the dividends received by the firms belonging to a business group, an optimal solution to the problem of minimizing the group tax burden exists. The optimal solution involves a gain in value for the group as a whole; nevertheless, since in business groups ownership is often differentiated among shareholders (often because of the separation between ownership and control), income shifting may determine wealth transfers, often in favor of the controlling shareholder. We therefore analyze the management and governance implications of such income shifting, for both shareholders and stakeholders (i.e. managers). This revised version was published online in July 2006 with corrections to the Cover Date.     

The effect of risk on the value of lost international business profits

The primary goal for providing damages for loss of business profits to a plaintiff, is to make the plaintiff whole with regards to monetary losses suffered. When the loss of profits results from international operations, the determination of the loss is more complex than from domestic operations, since political and currency risk need to be considered in addition to business risk. When lost profits occur in the future, these need to be discounted to present value. The discount rate used to discount these profits should be adjusted to acount for the risk associated with these future lost profits.     

网络购物平台最优价格促销策略：价格折扣还是现金券？

平台价格促销已成为平台营销中的重要问题，不同于传统模式下商家决定商品的价格促销，平台价格促销是以平台作为价格促销的决策者。本文建立了平台价格折扣和现金券两种由平台作为决策者的价格促销模型，探讨平台的最优价格促销策略，并在原有模型的基础上考虑商家广告投资决策并构建了扩展模型。研究结果表明，(1)只有当商品的基本需求、消费者价格敏感度和商品价格满足一定条件时，平台价格促销才能提升平台利润。(2)在两种价格促销都能提升平台利润情况下，平台的交易费率较高且商品价格较低则平台实施现金券策略的利润高于价格折扣策略；其他情况下平台实施价格折扣策略的利润高于现金券策略。(3)在平台交易费率较低的情况下，价格折扣策略下消费者能得到更多优惠；否则现金券策略下消费者得到更多优惠。(4)增加商家广告投资能够提高平台促销活动的利润，但是平台的价格优惠降低，且平台实施价格促销活动的条件区间减小。     

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.     

基于税盾效应的供应链贸易信用融资优化决策研究

针对中小企业融资困境的现实,本文基于贸易信用融资模式,引入税盾效应,建立了由单一核心供应商和单一经销商组成的含税盾的贸易信用模型,探讨有融资需求的经销商进行订货、核心供应商定价的决定策略,探究不同计息方式的价值实现和融资模式优选。通过stackbelberg博弈、比较分析和算例验证,研究发现以订货量确定为基准,融资需求出现的时点对供应链企业计息方式的选择均有影响。税法关于利息抵扣上限、贸易信用贷款利率、订货量等均影响经销商计息方式的选择,融资额度影响其订货策略;生产成本的差额、定价策略影响供应商的计息方式。     

Transfer Pricing and Sourcing Strategies for Multinational Firms

Taking advantage of low tax rates using transfer pricing and taking advantage of low production costs using offshoring are two strategies multinational firms (MNFs) use to increase profits. We identify an important trade‐off that MNFs face in setting their transfer prices: the conflict between (i) the incentive role and (ii) the tax role of the transfer price. For MNFs, we find the profit‐maximizing transfer‐pricing strategies that motivate divisional management to (i) make good sourcing decisions and (ii) take advantage of favorable tax rates. We quantify the absolute and relative maximum inefficiency in terms of the after‐tax MNF's profit change from using a single transfer‐pricing system as compared to the dual transfer‐pricing system. We show that the highest relative loss is attained when the average sourcing cost and the tax differential are high. We demonstrate that the highest absolute loss is attained when the average outsourcing cost is approximately equal to the offshoring cost. We extend our results to two practical variations in MNF structures: an MNF that faces operational constraints on its offshoring capacity and an MNF that uses compensation contracts linked to after‐tax firm‐wide profits. Our insights help MNFs' managers identify when to use single and dual transfer‐pricing systems.     

Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation,intragroup debt,and leases

The European Commission has been supporting a transition from a system of separate accounting to formula apportionment. After its 2011 draft directive was rejected by the Council, the Commission presented two new draft directives in October 2016, one stipulating rules for a common tax base and another the terms for consolidation and apportionment. The aspired system of unitary taxation is considered more resistant to profit shifting and assumed to reduce compliance costs. However, there are also doubts about the extent, to which such a system will eradicate tax-planning activities of MNEs. Other concerns have arisen about the practical issue of enforcing uniform rules for asset valuation throughout the member states. We use a dynamic model of tax accounting based on neoclassical investment theory and effective tax rates to determine to what extent formula apportionment mitigates the efficiency of typical profit-shifting strategies. We focus on the roles of transfer pricing and intragroup debt financing (through loans and leases) under both separate accounting and formula apportionment. We also take into account a possible leeway for inconsistent valuation. Our results show that instead of eliminating tax planning strategies, the proposed system might simply induce a shift from manipulating reported profits to influencing the apportionment key. Inside the European Union, the CCCTB may be able to render thin capitalisation rules and transfer pricing documentation redundant. However, formula apportionment invites for new forms of tax planning. It is therefore essential to give credit to these new kinds of tax incentives when implementing a system of unitary taxation.     

三种运营模式下O2O外卖服务供应链质量努力策略研究

O2O外卖作为"互联网+"时代下的新型餐饮模式，日益受到人们的关注。本文研究的O2O外卖服务供应链由一个O2O外卖平台、一个餐饮商家和一个配送骑手构成。O2O外卖平台决策平台的服务质量努力和服务费用，餐饮商家决策产品价格，骑手决策配送服务质量努力程度，同时会受到来自平台或商家的服务质量激励。通过分析商家配送、平台配送和商家自建平台+配送三种运营模式，分别构建O2O外卖服务供应链成员的利润函数，运用博弈理论，优化得到不同模式下O2O外卖服务供应链成员的最优质量控制策略和最优利润。利用公式推导和对比分析，分别探讨了骑手激励金额上限和市场规模对服务供应链最优策略和最优利润的影响。通过数值仿真，可得结论：服务供应链各成员利润均随着市场规模的增大而增大，随着骑手激励金额上限的增加而先增大后减少。当市场规模较小时，平台配送模式下商家最优利润最大。而当市场规模较大时，商家自建平台+配送模式下商家最优利润最大。     

Unternehmensbewertung bei wertabhängiger und autonomer Finanzierungspolitik unter Berücksichtigung einer Kursgewinnbesteuerung

The German tax reform in 2009 entails the general taxation of realized capital gains. The objective of this paper is to investigate the effect of a differentiated taxation of dividend payments and capital gains on discounted cash flow valuations. We develop explicit und practical useful valuation formulas for the free cash flow approach in case of financing based on market values and the adjusted present value approach in case of autonomous financing. Furthermore it is shown how the required risk-adjusted cost of equity can be derived from a modified Tax-CAPM. Finally we discuss how the particularities resulting from the new German tax law can be taken into account in discounted cash flow valuations.     

商业银行税务风险评估的实证分析

随着我国金融行业的飞速发展,商业银行所面临的税收压力越来越大,商业银行的管理层开始日益关注税务风险。税务风险有2种表现形式,即税负过重和税收处罚。根据15家上市商业银行2008～2010年的财务数据,构建了税负预警模型;采用税负对比法,对商业银行的税务风险进行了评估。分析结果表明,商业银行的营业税税务风险变化不大,但是企业所得税税负过重的商业银行有增多趋势。同时通过回归分析得出:营业收入、营业支出、营业税及附加、企业所得税对盈利综合税负有不同程度的影响。     

International business thought: A 50-year footprint

As international business marks 50 years of its establishment as a distinct domain of academic research, discussions on both the major contributions of the field and its future research directions have drawn great interest in the current literature. The arrival at a clear consensus on these issues, however, has been set back by the lack of resolution in the search for a unifying, integrative framework of international business. Drawing on theories of knowledge organisation and on extant reviews of international business research, this paper proposes an emergent international business research framework anchored around four unifying themes expressed as broad international business research questions. A content analysis of 1689 studies in the Journal of International Business Studies (JIBS) from its maiden issue in 1970 to 2008 and studies classified as international business in nature done prior to 1960 confirms the trajectories of international business research along the four themes. It is suggested that these major research themes serve as the main research pillars that define the international business domain, framing research done so far, and driving future research in the field. Areas of research intensity and opportunity are identified along with implications for international business research and theory-building.     

Strategic planning for international business

Although international business is old, today's problems deserve careful thought: the methods by which international strategic plans are made are capable of improvement in many companies. Further, much of today's international business has to face up to being multi-national, rather than international, which means that it exists in an environment which in many ways is not in step with its aims. The legal, political, social and economic climates bring many problems to the group which is endeavouring to be multi-national, problems which will be discussed later in this paper.     

终极控制、资本投向与配置绩效

基于终极股东自利动机与资本投向选择差异的理论阐释,实证考察了终极控制下的资本投向结构分布及其对总体投资绩效的影响.研究发现:1)终极股东的现金流权越低,越有增加固定资产、无形资产和股权并购的资本投入,以及削减R&D投资的动机;2)随着现金流权的降低,地方企业集团的固定资产投资规模和增速增大,地方资产公司的股权投资增长趋势更为强劲,这与两类地方国有终极股东的运营模式和谋利能力密切相关;3)由于获取特许和垄断性使用权的难度较大,民营终极股东自利动机对无形资产投资的影响不显著;4)终极股东自利动机下的投资选择,不仅降低了整体的资本配置绩效,而且导致投资结构的异化.上述研究结论,对于从产权角度来理解中国经济高速增长背后的微观投资的非效率成因具有重要意义,也为进一步改善技术创新投资的产权激励机制提供了理论依据.     

Die steuerliche Berücksichtigung von Refinanzierungsaufwendungen beim internationalen Unternehmenskauf

The possibility to deduct interest expenses resulting from financing international mergers & acquisitions for tax purposes affects the attractiveness of international mergers & acquisitions. Multinationals can use tax planning in order to achieve a tax favored deduction of such interest expenses. On the one hand multinationals can achieve a tax effective deduction of such interest expenses in the country of residency of the target firm using an acquisition vehicle in combination with group taxation or a merger. On the other hand multinationals can try to deduct such interest expenses in the subsidiary within the multinational group being subject to the highest tax rate. The deduction of interest expenses resulting from international mergers & acquisitions should not violate the economic principle of neutral taxation. Following this principle, the deduction of such interest expenses should be granted at exactly the tax rate, at which the profits of the acquired firm are subject to taxation.     

The impact of international business education on career success—Evidence from Europe

In today's globalized world, career paths are becoming increasingly international, and so managers need respective cross-cultural strengths in order to act effectively in various cultural environments. Even though education—especially business education—is progressively becoming more international to meet these organizational demands, little is known about whether the extent of international business education influences careers, and in particular career success. In addressing this research deficit, we explore whether and how international business education affects career success. As the major contribution of this paper we suggest a conceptual framework which posits global identity and international experience as mediators of this relationship. The assumptions of this framework are confirmed by an investigation amongst 450 alumni of a European business school. Additional contributions include that we extend the limited body of research on the construct of international business education and its measurement, by providing an all-encompassing definition and much-needed operationalization. Furthermore, we contribute a European perspective on international business education through our empirical evidence.     

Crafting business models for conflicting goals: Lessons from creative service firms

The business model construct has become attractive to both managers and academics. It reflects how the most important organization's strategic and tactical choices regarding the allocation of resources interact in order to create and capture value. Yet with the growing entrepreneurial complexity, managers often end up pursuing conflicting and even paradoxical strategic goals, thus rendering the business modelling processes more complex, too. Well-known examples are profit versus social value, stakeholder versus company interests, exploration versus exploitation and environmental sustainability versus economic returns. The academic business model literature so far has provided limited insights on how to implement business models beyond a single goal and focused mainly on the initial strategic choice of a business model, ignoring that such salient tensions are often persistent and resurface within the business practice. In this study we leverage paradox theory to investigate how managers of creative firms make tactical choices to accommodate (not solve) salient tensions within their business models, focusing on the domains like services provided, choice of clients, networking and resourcing practices, revenue models and new venture creation. Based on qualitative case study research, we found four integrating and three differentiating decision-making tactics that managers deploy to create both economic and creative value through their business models. Adding to the business model theory, we show how business models are crafted in managerial practices by making tactical decisions to solve conflicts and paradoxes. The results equally enrich the paradox literature by providing for tactical-level approaches toward working through the paradox.     

Forgotten travelers: Adjustment and career implications of international business travel for expatriates

In this study, we demonstrate the importance of assessing international business travel in the context of expatriation. Based on the Job Demands-Resources theory, we suggest that engaging in international business travel is beneficial for expatriates when certain conditions are in place and detrimental when they are not. We propose that expatriates who have adequate job resources will reap the benefits of international business travel and achieve better adjustment to living and working in the host country and have greater career satisfaction. Survey results based on a sample of 161 expatriates provide support that engaging in international business travel is positively and indirectly related to expatriates' career satisfaction through expatriate adjustment when job resources are abundant, and it has a negative indirect association when resources are low. We further find that job resources play a role in the relationship between international business travel and career satisfaction primarily when the host-country culture is similar to that of the home country.     

控股股东代理成本、纳税筹划方案抉择及其市场价值:基于J有限公司的案例研究

纳税筹划是实务界与学术界共同关心的领域,现有研究大量讨论了公司纳税筹划行为的决定因素及其经济后果,但仍存在巨大争议。一方面,纳税筹划节约了现金流,提升股东价值;另一方面,代理问题使企业的纳税筹划方案更可能有利于控股股东或管理层,而非上市公司利益最大化,从而可能降低企业价值,最终纳税筹划方案的经济后果取决于上述两方面的共同作用。本文基于某上市公司(J有限公司)收购大股东土地案例,分析了代理成本影响公司税务决策的路径及其经济后果。本文发现,控股股东构造了较为复杂的股权转移交易方式,为上市公司和控股股东节约了大量税务成本。但由于代理成本的存在,在多种纳税筹划方案中,控股股东并未选择对上市公司最为有利的方案,而选择了能够取得现金最多,控股股东利益最大化的方案。进一步的研究发现,市场非常关注该企业的纳税筹划行为,与本文搜集的对照样本相比,尽管J公司的控股股东未选择最优的方案,但投资者仍给予了该纳税筹划行为以积极反应,提升了企业价值。本文为研究代理成本影响公司税务决策的机理提供了重要参考。