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Taxation, Financial Intermodality and the Least Taxed Path for Circulating Income within a Multinational Enterprise

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  • Marcel Gerard
  • Marie-France Gillard

Abstract

When minimizing their overall tax liabilities, multinational enter prises exploit the various provisions of interiurisdictional tax arrangements, not hes itating to circulate flows indirectly and through various financial vehicles. This pape proposes to nest modeling such strategies into graph theory and network analysis. Such an exercise enables to compute strategy supported effective tax rates and to question the design of interjurisdictional tax arrangements.

Suggested Citation

  • Marcel Gerard & Marie-France Gillard, 2004. "Taxation, Financial Intermodality and the Least Taxed Path for Circulating Income within a Multinational Enterprise," Annals of Economics and Statistics, GENES, issue 75-76, pages 89-107.
    • Handle: RePEc:adr:anecst:y:2004:i:75-76:p:89-107
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    File URL: http://www.jstor.org/stable/20079096
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    Cited by:

    1. Fernando Ruiz, 2006. "Convergence de l'impôt sur les sociétés dans lUnion européenne," Économie et Prévision, Programme National Persée, vol. 173(2), pages 79-96.
    2. Marcel Gérard, 2006. "Reforming the taxation of multijurisdictional enterprises in Europe: a tentative appraisal," European Economy - Economic Papers 2008 - 2015 265, Directorate General Economic and Financial Affairs (DG ECFIN), European Commission.
    3. Sung Jae Park & Kyu-Min Lee & Jae-Suk Yang, 2021. "Navigating optimal treaty-shopping routes using a multiplex network model," PLOS ONE, Public Library of Science, vol. 16(8), pages 1-16, August.
    4. Anken, F. & Beasley, J.E., 2012. "Corporate structure optimisation for multinational companies," Omega, Elsevier, vol. 40(2), pages 230-243, April.
    5. Maarten ‘t Riet & Arjan Lejour, 2018. "Optimal tax routing: network analysis of FDI diversion," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(5), pages 1321-1371, October.
    6. Park, Sung Jae & Lee, Kyu-Min & Yang, Jae-Suk, 2023. "Calculating the country risk embedded in treaty-shopping networks," Technological Forecasting and Social Change, Elsevier, vol. 189(C).
    7. Marcel Gérard, 2005. "Multijurisdictional Firms and Governments’ Strategies under Alternative Tax Designs," CESifo Working Paper Series 1527, CESifo.
    8. Maarten ‘t Riet & Arjan Lejour, 2018. "Optimal tax routing: network analysis of FDI diversion," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(5), pages 1321-1371, October.

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