| Summary: | 碩士 === 輔仁大學 === 企業管理學系管理學碩士在職專班 === 107 === It has been a rule for multinational firms to minimize their tax burdens through global arrangement of tax locations so as to take advantage from tax differences among regions. However, the tax arrangement, from the tax authority’s perspective, is subject to the concern of Base Erosion and Profit Sharing (BEPS). This is now becoming a sensitive and touchy issue from the lens of international tax law.
The Organization for Economic Cooperation and Development issued 15 Standards for Automatic Exchange of Financial Account Information (AEOI), which provides the guild line for tax authorities to stipulate a series of anti-avoidance measures and to form the basis for information exchanges. In this study, I use four cases to thoroughly investigate how firms react to the regulatory changes in tax avoidance rules. Specifically, issues covered include Controlled Foreign Company Rule (CFC), Place of Effective Management (PEM), Transfer Pricing (TP), International Tax Co-operation Economic Substance Law (ITCESL), and Common Reporting Standard for Automatic Exchange of Financial Account Information in Tax Matters (CRS). Through in-depth interviews I develop several propositions to illustrate firm’s responses to changes in tax rules. To sum up, the major factors dictate firm’s responses include cost-benefit analysis, the need of earnings smoothing, and family succession plan.
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