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Interest payments received are subject to tax in the low-tax country. Again, profit is shifted from the high-tax country to the low-tax country and the multinational can take advantage of the international tax rate differential. European Tax Planning Europe is an especially challenging area for international tax planning because there are remarkable differences in corporation tax rates across European countries. 10 Internationally diverging corporation tax rates give rise to international tax planning by means of tax rate arbitrage.

Taxes may also affect market prices, thus impacting on gross cash flows. The investors could, for example, shift the income tax burden to employees through lower wages or to customers through higher prices. In the following, it is assumed that the profit tax burden cannot be shifted away to other parties. All other things being equal, a reduction of the investment’s net cash flows reduces the NPV. Secondly, taxes affect the yield of the capital market investment. If the financial investment is taxed, the interest rate has to be cut by the tax rate applied to financial investments.

Taking sales into account, allocates a company’s profit to countries where goods are delivered or services performed. Although it seems to be plausible from an economic point of view to allocate a company’s total profit according to factors that are related to production and sales, it is essentially unclear what amount of profit is “caused” by invested capital and employed workforce or generated revenues. We lack any economic theory how to allocate a firm’s profit fairly according to the input factors involved.

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