Research background: The problem of base erosion and profit shifting by multi-national corporations has been debated from different perspectives because of its multiple impact on the key actors in the economy. Studies refer to its positive impact on companies via corporate taxes saved, but its negative impact on governments via reduced tax collection. A number of empirical studies conducted in different countries support the substantial BEPS impact on company performance, but report differences in its magnitude. Other authors claim that, despite a wide range of tax avoidance opportunities available, tax avoidance is limited due to institutional measures imposed (tax audits, penalties for non-compliance) and high implementation costs. A majority of the previous empirical research covered large countries (USA, Germany) or regions (e.g. Europe), but there is a gap in the re-search assessing the BEPS impact on multinational corporations’ subsidiaries’ performance in countries with lower corporate income tax rates such as the Baltic countries. Purpose of the article: To assess the impact of base erosion and profit shifting on multinational corporations’ subsidiaries’ performance in the Baltic countries. Methods: Empirical research is conducted based on the framework employed by Hines and Rice (1994) to measure BEPS impact on company performance. Regression analysis with fixed effects was applied to a sample of 3,422 Latvian, Lithuanian and Estonian subsidiaries of multinational corporations, which are characterized by low corporate tax rates.  The data for the period of 2007–2015 was retrieved from the Amadeus database. Findings & Value added: The research revealed that Baltic countries’ tax differentials between multinational corporations’ parent and subsidiary countries might have a significant impact on the subsidiary’s financial performance. When the tax rate differences between Baltic and the foreign countries decrease by 1%, reported profits in Baltic countries increase by 2.3%, indicating profit-shifting behaviour. This is in line with the empirical literature and practices applied by multinational corporations. It is also in favour of anti-tax avoidance measures introduced by the EC to be adopted by Baltic and other EU countries.

Research background: Multinational enterprises (MNEs) employ tax avoidance by ability to use differences in tax systems of various countries to successfully incur effective tax rate that is lower than the statutory one. Literature analysis revealed that previous research rarely concentrated on profit shifting practices in small economies. It mostly covered large countries (USA, Germany) or regions (e.g. Europe). Research on Lithuania, as a small open economy characterized by lower corporate income tax rates, is a relevant case for the analysis. Purpose of the article: The purpose of the article is to assess profit shifting via transfer mispricing in Lithuanian companies. Methods: Regression analysis with fixed effects was applied to a sample of 3,563 Lithuanian companies for the period of 2010–2018. The data was retrieved from Amadeus database. Findings & Value added: The results of testing profit shifting channel – transfer mispricing – showed that tax incentives significantly affect earnings of MNEs in the sample while results of domestic firms are puzzling. Earnings of multinationals in the sample are strongly affected by statutory tax rate difference between the subsidiary operating in Lithuania and the parent company in a foreign country. Such results may imply that in small economies like Lithuania (characterized by lower tax rates and lower tax avoidance costs) profit shifting via transfer mispricing is used by MNEs as a channel of corporate tax avoidance.

Research background: Base erosion and profit shifting (BEPS) is a reduction of corporate income tax base and related corporate income tax payments via taking advantage of tax loopholes. OECD prepared 15 BEPS actions, which set countermeasures to fight tax avoid-ance in a coordinated way and shall be implement by countries on a voluntary basis. Literature review revealed that on a macro-level and company-level the extent of BEPS is large and statistically significant while studies addressing micro-level (transaction-level) impact and BEPS countermeasures’ related issues are limited. Purpose of the article: to identify methods and metrics available for evaluation of BEPS countermeasures’ impact on a micro-level and to assess BEPS countermeasures’ impact on a business group. Methods: the paper employs comparative analysis of scientific and professional literature to identify approaches and methods available for evaluation of BEPS countermeasures’ impact on a micro-level; and a case analysis method to assess an expected impact of BEPS coun-termeasures on a specific business group.  Findings & Value added: An approach used to estimate BEPS countermeasures impact on the micro-level differs from the one applied in macro-level analysis. To conduct the case analysis, OECD’s proposed macro-level fiscal impact assessment approach has been adapted for a micro-level analysis. It includes the analysis of the transactions subject to BEPS countermeasures and develops an action plan to manage related risks. The conducted case analysis differs from previous research as it employs transaction-level data and estimates fiscal effect of BEPS countermeasures on a micro-level. Analysis of the activities of the specific business group revealed that 5 from 15 countermeasures are relevant and directly applicable to this business group. They would not have an immediate significant direct fiscal effect, but risks related to BEPS countermeasures exist and action plans to manage negative effects of BEPS countermeasures have to be implemented.

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