“Beskatning af derivater. En analyse af dansk skatteret”

Supervisors;

Professor Jane Bolander

Juridisk Institut

CBS

Jakob Bundgaard, Ph.D.,

Adm.  direktør, CORIT Advisory P/S,

Adjungeret professor,

Aarhus Universitet

Assessment Committee;

Professor Peter Møgelvang-Hansen (chair)

Juridisk Institut

CBS

Professor Mattias Dahlberg

Juridiska Institutionen

Uppsala Universitet

Professor Aage Michelsen

Juridisk Institut

Aarhus Universitet

Moreover Jakob Bundgaard has been invited to deliver a speech at the Vienna Institute of Austrian and International Tax Law on 18-19 May 2012.

“ Fradragsbeskæring af selskabers    finansieringsudgifter – en skatteretlig analyse af SEL §§ 11, 11B og 11C””

Supervisors;
Associate Professor Kim Østergaard
Juridisk Institut
CBS

Jakob Bundgaard, Ph.D.,
Adm.  direktør, CORIT Advisory P/S,
Adjungeret professor, Aarhus
Universitet

Assessment Committee;
Professor Jane Bolander (formand)
Juridisk Institut
CBS

Søren Næsborg Jensen
KPMG Danmark

Lektor Hugo Matre
Faculty of Law
University of Bergen

Time and place
30 March, 2012
13:00-15:00

Copenhagen Business School
Solbjerg Plads 3
2000 Frederiksberg,
Room: SPs08

Thesis
The thesis will be available from http://openarchive.cbs.dk
approx. one week before the defense

Reception
After the defence LIMAC PhD School hosts a reception at Solbjerg Plads 3 in “Rotunden” on second floor (above the canteen)

The adress is: Lyngby Hovedgade 17, 2nd. floor., DK-2800 Kongens Lyngby.

The choice is made on the basis of a numbers of relevant factors. Kongens Lyngby is a university city with a large population of innovative and important companies. Moreover, the city has formulated a strategy to become a significant knowledge- and university city in northern Europe. Moreover, the city has the ambition to be an international hotspot for labour, culture and trade.

This strategy is perfectly aligned with the CORIT ambition and we consider it a perfect match for future devepment of CORIT and we also look forward to participate in the fulfillment of the city’s strategy.

We look forward to welcome you in our new offices.

•  Introductory Chapter: Evidence of Corporate Profit Shifting
• Thin Capitalization and Interest Deduction Regulations: A Worldwide Survey
• The Tax Efficient Supply Chain: Considerations for Multinationals
• Escaping the U.S. Tax System: from Corporate Inversions to Re-domiciling
• The IRS Investor Model

The dissertation analyzes ways in which Multinational Enterprises (MNEs) shift profits from one country to another to reduce their income tax expense. This is an important topic for a number of reasons. From a country‘s perspective, its income tax rates and policies can have a significant impact upon its tax revenue, economic competitiveness, and the vibrancy of its economy. From the MNE‘s perspective, income tax rates and policies determine a firm‘s tax obligations, and thus affect net income and enterprise value. The dissertation examines several ways in which MNEs shift profits to reduce income taxes, and consists of five chapters.

The introductory chapter reviews the economic evidence demonstrating firms shift profits from one country to another in response to tax rates. In the past two decades a number of economic studies have shown firms use tax and accounting techniques to shift reported profits to low tax jurisdictions, and that chapter reviews key articles that have demonstrated this. The second paper explains how MNEs finance international investments to shift interest income to low-tax jurisdictions. It reviews government tax policies in a number of countries that have been enacted to limit interest income shifting, and recommends an approach to control this activity. The third paper examines tax efficient supply chains, in which tax departments and supply chain organizations collaborate to site business operations to achieve supply chain objectives and reduce tax obligations. The fourth chapter analyzes how some U.S.-headquartered firms have moved their corporate headquarters from the U.S. to tax havens, to reduce their tax expense and avoid U.S. international tax policies. The fifth and final chapter examines new U.S. tax regulations that propose to value intellectual property transfers in the same way outside investors would, which the U.S. Internal Revenue Service (IRS) calls its ―investor model. It also makes recommendations concerning how the investor model can be improved. This dissertation draws upon a number of academic disciplines, including economics, finance, supply chain management, and tax law. It does not fit into a single academic category, and it seeks to make a contribution by drawing upon these various disciplines to recommend ways countries can tax economic activity in fair and effective ways, and suggest ways firms can minimize tax obligations while still complying with international tax laws.

The dissertation consist in a literature review and three empircal papers, illustrating the way management control and cost accounting systems can be designed for transfer pricing tax compliance purposes in the MNE.

Christian will continue in academia and do more research on international transfer pricing, integrating the accounting and taxation discipline.

If you are interested in research/teaching collaboration, Christian can be reached at cro.acc@cbs.dk

CORIT

The conference is hosted in co-operation with Danish Venture Capital & Private Equity Association (DVCA) and Copenhagen Business School and will consist of 3 keynote speeches and 8 panels providing their view on intriguing topics within the industry. These panels are composed by top professionals within private equity from companies such as Goldman Sachs Capital Partners, Kohlberg Kravis Roberts, J.P. Morgan, McKinsey & Company, Boston Consulting Group, EQT, Axcel, Credit Suisse, Morgan Stanley, TDC, Booz & Co. and many, many more.

For more information, please go to http://www.pe-conference.com/.

Invitation

Agenda

Poster

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