improve corporate reputation and regain public trust, corporate social responsibility (CSR) is a helpful tool.
Currently, many companies embrace CSR, which entails several kinds of obligations towards the society (§6). The question is, however, whether a business’ CSR should also reflect (moral) leadership in relation to its tax strategy? Moreover, does the ethical obligation to go beyond what is required by the law - key to CSR companies - encompass, for instance, tax transparency? These questions structure this article. It will be argued that in light of CSR, good
Society expects companies to take into account the economic, environmental, and social effects of their operations and activities. The concept of corporate social responsibility (CSR) refers to the operations or actions of companies that are above or independent of the limits or minimum requirements set by legislation.
The economic purpose of a company and its responsibilities towards shareholders and debtors, first and foremost, is a natural starting point in reviewing the responsibilities. Also other stakeholders such as employers or public entities as tax collectors have economic requirements and expectations. Responsibility in the context of tax issues has become the topic of greater attention, with a number of stakeholder groups actively reviewing the approaches that companies take to their tax strategies and tax planning activities.
In this article CSR is reviewed especially in the context of taxation. Does CSR have any significance and importance in the context of tax law and especially income taxation? Does CSR set limits on the tax planning of companies, or is there an obligation to pay any more taxes than what has to be paid according to the law and the tax treaties? While the concept of CSR is not a legal one, neither is the approach for these questions in this article only a legal one.
Attitudes towards taxes are often contradictory. On the one hand, taxes are like any other costs for a company, but on the other hand, they are an economic contribution to the society in which the business is conducted.
The phrase “aggressive tax planning”, as opposed to regular or “acceptable” tax planning, has been used on several occasions recently. Taking a purely technical approach to tax planning is unlikely to protect companies from charges of irresponsibility and associated reputational damage. Aggressive tax planning can be characterized, for instance, by an intensive use of legal and financial tools, establishments in foreign tax havens, unbalanced capital structures and transfer prices, or a disingenuous use of tax treaties.
Still, aggressive tax planning is not a legal concept so there is no legal definition for it. Instead, the question is more or less about where to draw the line of moral acceptability, which runs on the inside of the tax planning area. From the CSR point of view, aggressive tax planning can be defined as actions taken by taxpayers which are in the line of requirements of tax law, but which do not meet the reasonable and justified expectations and requirements of the stakeholders.
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Chapters 2-5 serve as building blocks needed for conducting the comparative analysis in Part 2. Therefore, each chapter is a presentation of the theoretical and juridical tools that are to be used in the analysis. The theory and the tools are known, but, nevertheless, the author manages to present them in a short and well-structured manner.
The DTAs form one building block, which is presented in Chapter 2. After a short survey on the purpose and use of DTAs and the role of OECD, the focus in Chapter 2 is on the abuse of double tax agreements
strategy balancers as firms that use exceptional accounting items as earnings management tools. The prediction is that such firms are able to generate high book income and low tax income without affecting the association between financial and tax accounting. They find that these firms engage in less earnings management via standard accounting items than other firms in the event of a CTR cut.
In a related paper, Lin et al . (2014) examine the private and public firm response to a CTR reduction from 33
percent to 25 percent in China. The results indicate that the
Soviet authorities as a very important and useful ideological tool to demonstrate the intellectual superiority of the Soviet communist regime over the decadent West.” See ( Cristol 2019 ) Iceland was opening up to new ideas and trends from abroad, as many journalists from abroad visited Reykjavík to cover the tournament, which in turn increased interest in Iceland internationally, along with the curiosity of Icelanders regarding foreign affairs.
A new government established a committee to revise the tax system. The committee delivered a detailed report in 1973. The
indirect impact on how society can fulfill its tasks and obligations. Therefore, tax issues can be included on the social factors agenda as well. Furthermore, taxation is one of the most important tools in environmental protection as well. Although this link is very strong at the level of tax policy, it is harder to see that in ESG analyses taxes would have any particular role when assessing a company’s environmental responsibility.
The current study attempts to clarify and understand the role played by corporate taxes in the context of SRI. First, while the
family, British law (and not Indian or Australian law) is the parent jurisdiction ( Zweigert and Kötz (1998) ). This idea of using legal families as a tool for comparative studies is based upon the assumption that the material of a comparison might be reduced by way of generalization ( Rainer (2010) ). Comparing all jurisdictions in the world would be impossible or at least very difficult. It would therefore simplify the working process of a comparative study if a few representative jurisdictions could be identified.
The classification and division into legal
use the term as system thinking. The view of lean has developed and changed over the years and it can be difficult to know exactly what the concept stands for ( Innovationsrådet (2012) ). 9 Modig and Åhlström divide lean into three levels 1. Lean as a philosophy, culture and values etc. 2. Lean as a means of improvement, quality assurance system, production system etc., and 3. Lean as metods, tools, elimination of waste etc. See Modig, Niklas and Åhlström, Pär, Vad är Lean?. It could be described as a “travelling idea” ( Quist 2003 ). Lean can be
travaux préparatoires as a tool for the interpretation of Swedish law, until the 1990s, when it was followed by a more critical approach to contents that could be in conflict with unambiguous statutory wording ( Tjernberg (2003) ). In some cases, however, the Supreme Administrative Court has recently disregarded specific isolated wording in the legislation explicitly, in favor of a systematic interpretation that is closer to the spirit of the travaux préparatoires (see Rydin (2014) ; Tjernberg (2015) . In Finland, great emphasis is also placed on the principle of