The link approach to measuring consumer surplus in transport networks

Should one calculate user benefits from changes in door-to-door journeys or from changes in the use of separate links of the network? The second approach is often discarded for its perceived inability to deal with new links and the OD-matrix approach is favoured. Differences arise when the set of used routes changes. A consumer model containing a general static transportation network with explicit non-negativity constraints serves as a basis for welfare measures expressed in shadow prices. The approximation error when applying the link approach need not be too severe. A rehabilitation of the link approach may be in order.

Disentangling Business- and Tax-Motivated Bilateral Royalty Flows

Shifting intellectual property (IP) rights across jurisdictions is a well-known strategy of multinationals to reduce corporate income taxation. We investigate the extent to which the flows of remunerations for the use of IP rights are affected by differences in corporate income and withholding taxation. Using OECD data between 2014 and 2019, we determine the influence of bilateral tax rates on the IP-location. These rates result from a network analysis that distinguishes between the potential gains from direct shifting of IP rights and treaty shopping. The latter are gains for multinationals from exploiting lower withholding taxes by routing royalty flows through conduit countries. We use these bilateral tax gains to isolate the flows that could be only businessmotivated. Next we apply a gravity framework with PPML estimators. We estimate that at least 18% of the royalty flows is motivated by tax planning in this period, which reduces tax revenues by 6.5 to 16 billion US dollar in 2018. We argue that both estimates are lower bounds due to missing observations. More reporting by OECD countries of flows to and from tax havens would improve the precision of the estimates. To the best of our knowledge these are the first estimates of worldwide tax avoidance with royalties

Limitation of Holding Structures for Intra-EU Dividends: Limitation of Holding Structures for Intra-EU Dividends:A Blow to Tax Avoidance?

This article analyses the recent rulings from the European Court of Justice in two Danish cases and examines their possible impact on international tax avoidance. These rulings regard limitations of tax benefits related to cross-border dividends and interest payments resulting from the interposition of holding companies in the EU. We conclude that from a legal perspective, the rulings demonstrate the alignment of international tax policies to combat tax avoidance between the EU and the OECD. This alignment is historical in international tax law as it encompasses a record-high number of states and because it introduces a minimum standard of tools to combat tax treaty abuse directly into national state legislation. This could be the end for certain tax-motivated structures of international companies. From a quantitative perspective, the conclusion is that the rulings limit the potential for Multinational Enterprises to lower their tax burden considerably. The worldwide average potential gain from treaty shopping is reduced by 1.1 percentage points from 5.6% to 4.5% when the EU member states cannot be used on treaty shopping routes. With more countries, and treaties, involved, the combat against tax avoidance is more effective. However, the fact that some countries have a standard withholding tax rate of zero percent hampers the combat. If a prohibitive penalty is applied on indirect routes to all partner countries, the policy is much more effective. The gains from treaty shopping all but disappear in such a setting

Factors Associated with Revision Surgery after Internal Fixation of Hip Fractures

Background: Femoral neck fractures are associated with high rates of revision surgery after management with internal fixation. Using data from the Fixation using Alternative Implants for the Treatment of Hip fractures (FAITH) trial evaluating methods of internal fixation in patients with femoral neck fractures, we investigated associations between baseline and surgical factors and the need for revision surgery to promote healing, relieve pain, treat infection or improve function over 24 months postsurgery. Additionally, we investigated factors associated with (1) hardware removal and (2) implant exchange from cancellous screws (CS) or sliding hip screw (SHS) to total hip arthroplasty, hemiarthroplasty, or another internal fixation device. Methods: We identified 15 potential factors a priori that may be associated with revision surgery, 7 with hardware removal, and 14 with implant exchange. We used multivariable Cox proportional hazards analyses in our investigation. Results: Factors associated with increased risk of revision surgery included: female sex, [hazard ratio (HR) 1.79, 95% confidence interval (CI) 1.25-2.50; P = 0.001], higher body mass index (fo

Tax Treaty Shopping and Developing Countries: Serious Potential for Tax Revenue Loss

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are not, on average, more likely to suffer from tax revenue losses than other countries. Yet, this average masks that several countries, such as Bangladesh, Egypt, Kenya, Indonesia, Uganda and Zambia, are all vulnerable to substantial potential losses of withholding tax revenue by treaty shopping. The treaties responsible for this are referred to as potentially aggressive tax treaties. This is concluded by two Dutch economists and tax scholars, in a study commissioned by ICTD. Summary of Working Paper 173

Aanpak belastingontwijking nauwelijks terug te zien in de data

Drie jaar geleden riepen Arjan Lejour en Maarten van 't Riet op om de Nederlandse aanpak van belastingontwijking door multinationals via Nederland te evalueren aan de hand van de data. Het kabinet-Rutte III had in februari 2018 haar strategie tegen deze vorm van belastingontwijking aangekondigd. Wat is daar inmiddels van terecht gekomen

Aanpak belasting ontwijking? Laat het zien in de data!

De slechte internationale reputatie van Nederland op het gebied van belastingontwijking wordt mede veroorzaakt door de plek van Nederland in internationale financiële statistieken. Het lijkt het huidige kabinet ernst met het aanpakken hiervan. CPB-economen Lejour en van ’t Riet betogen dat de reputatie-schade pas kan herstellen als de effecten van nieuw beleid tegen belastingontwijking ook daadwerkelijk zichtbaar worden in die statistieken

Tax Treaty Shopping and Developing Countries

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh, Egypt, Indonesia, Kenya, Uganda and Zambia, are vulnerable to substantial potential losses of withholding tax revenue by treaty shopping. The treaties responsible for this are referred to as potentially aggressive tax treaties.Foreign, Commonwealth & Development OfficeBill & Melinda Gates FoundationNorwegian Agency for Development Cooperatio