{"title":"通过高级税收裁定进行税收筹划——利用卢森堡税收泄密进行探索性分析","authors":"Oliver Zhen Li, Stephen J. Lusch, Frank Murphy","doi":"10.1080/09638180.2023.2182336","DOIUrl":null,"url":null,"abstract":"We use Luxembourg advanced tax rulings (ATRs) to provide readers with insight into the nature of tax planning that uses ATRs. Accordingly, we descriptively examine this sample of leaked Luxembourg ATRs and evaluate the determinants and outcomes associated with requesting a Luxembourg ATR. We find that the determinants of requesting an ATR differ between financial services firms and industrial firms. We document a positive spillover market reaction to non-ATR firms sharing characteristics of ATR firms. While prior research documents a positive association between ATRs and tax avoidance, we fail to document a significant relations between ATRs and tax risk. We do, however, find that firms that are required to disclose unrecognized tax benefits in their financial statements record higher UTBs after requesting an ATR, which suggests that ATRs may lead to higher uncertainty in jurisdictions not covered by the ATR itself. Our research provides insight into transactions used by MNEs to move income through organizations.","PeriodicalId":11764,"journal":{"name":"European Accounting Review","volume":null,"pages":null},"PeriodicalIF":2.5000,"publicationDate":"2023-03-16","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":"1","resultStr":"{\"title\":\"Tax Planning Through Advanced Tax Rulings – An Exploratory Analysis Using the Luxembourg Tax Leaks\",\"authors\":\"Oliver Zhen Li, Stephen J. Lusch, Frank Murphy\",\"doi\":\"10.1080/09638180.2023.2182336\",\"DOIUrl\":null,\"url\":null,\"abstract\":\"We use Luxembourg advanced tax rulings (ATRs) to provide readers with insight into the nature of tax planning that uses ATRs. Accordingly, we descriptively examine this sample of leaked Luxembourg ATRs and evaluate the determinants and outcomes associated with requesting a Luxembourg ATR. We find that the determinants of requesting an ATR differ between financial services firms and industrial firms. We document a positive spillover market reaction to non-ATR firms sharing characteristics of ATR firms. While prior research documents a positive association between ATRs and tax avoidance, we fail to document a significant relations between ATRs and tax risk. We do, however, find that firms that are required to disclose unrecognized tax benefits in their financial statements record higher UTBs after requesting an ATR, which suggests that ATRs may lead to higher uncertainty in jurisdictions not covered by the ATR itself. Our research provides insight into transactions used by MNEs to move income through organizations.\",\"PeriodicalId\":11764,\"journal\":{\"name\":\"European Accounting Review\",\"volume\":null,\"pages\":null},\"PeriodicalIF\":2.5000,\"publicationDate\":\"2023-03-16\",\"publicationTypes\":\"Journal Article\",\"fieldsOfStudy\":null,\"isOpenAccess\":false,\"openAccessPdf\":\"\",\"citationCount\":\"1\",\"resultStr\":null,\"platform\":\"Semanticscholar\",\"paperid\":null,\"PeriodicalName\":\"European Accounting Review\",\"FirstCategoryId\":\"1085\",\"ListUrlMain\":\"https://doi.org/10.1080/09638180.2023.2182336\",\"RegionNum\":3,\"RegionCategory\":\"管理学\",\"ArticlePicture\":[],\"TitleCN\":null,\"AbstractTextCN\":null,\"PMCID\":null,\"EPubDate\":\"\",\"PubModel\":\"\",\"JCR\":\"Q2\",\"JCRName\":\"BUSINESS, FINANCE\",\"Score\":null,\"Total\":0}","platform":"Semanticscholar","paperid":null,"PeriodicalName":"European Accounting Review","FirstCategoryId":"1085","ListUrlMain":"https://doi.org/10.1080/09638180.2023.2182336","RegionNum":3,"RegionCategory":"管理学","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":null,"EPubDate":"","PubModel":"","JCR":"Q2","JCRName":"BUSINESS, FINANCE","Score":null,"Total":0}
Tax Planning Through Advanced Tax Rulings – An Exploratory Analysis Using the Luxembourg Tax Leaks
We use Luxembourg advanced tax rulings (ATRs) to provide readers with insight into the nature of tax planning that uses ATRs. Accordingly, we descriptively examine this sample of leaked Luxembourg ATRs and evaluate the determinants and outcomes associated with requesting a Luxembourg ATR. We find that the determinants of requesting an ATR differ between financial services firms and industrial firms. We document a positive spillover market reaction to non-ATR firms sharing characteristics of ATR firms. While prior research documents a positive association between ATRs and tax avoidance, we fail to document a significant relations between ATRs and tax risk. We do, however, find that firms that are required to disclose unrecognized tax benefits in their financial statements record higher UTBs after requesting an ATR, which suggests that ATRs may lead to higher uncertainty in jurisdictions not covered by the ATR itself. Our research provides insight into transactions used by MNEs to move income through organizations.
期刊介绍:
Devoted to the advancement of accounting knowledge, it provides a forum for the publication of high quality accounting research manuscripts. The journal acknowledges its European origins and the distinctive variety of the European accounting research community. Conscious of these origins, European Accounting Review emphasises openness and flexibility, not only regarding the substantive issues of accounting research, but also with respect to paradigms, methodologies and styles of conducting that research. Though European Accounting Review is a truly international journal, it also holds a unique position as it is the only accounting journal to provide a European forum for the reporting of accounting research.