Page 19 - Strategic Tax Planning for Global Commerce & Investment
P. 19

Strategic Tax Planning for Global Commerce and Investment


             Benchmarking and Tax Rate Drivers


             An important first step in developing a global tax strategy and
             plan is to make an assessment of the MNEs ETR relative to its
             peers or similar companies and evaluate the factors driving the
             company’s profit and related tax burden. In other words, it is
             important to understand de MNEs profit and tax drivers and
             whether  and  why  the  company  compares  favorable  or
             unfavorable to similar companies.


             Benchmarking  of  global  tax  efficiency  is  the  best  way  to
             determine  whether  tax  cost  can  or  should  be  reduced.  This
             analysis involves determining the appropriate benchmark and
             the  right  companies  to  benchmark  against.  The  appropriate
             benchmarks are typical ETR and cash tax rate.


             Further,  this  analysis  involves  understanding  the  company’s
             profit  drivers  and  identifying  and  rank  ordering  the
             corresponding  tax  rate  drivers  that  underpin  the  MNEs
             worldwide tax position. A tax rate driver can be defined as any
             major financial or operational influence  on a company’s ETR.
             Profit  drivers,  and  thus  tax  drivers,  generally  fall  into  two
             categories:    financial  profit  drivers  and  functional  profit
             drivers.


             1.  Financial Profit Drivers

             Financial profit drivers relate to financial risk. Financial profits
             represent the return on external and internal business risks and
             capital  investments.  They  include  return  on  inventory  risks,
             accounts receivable risks, warranty risks and foreign exchange
             risks. They also include the return from internal deployment of
             capital  and  other  income  producing  assets.  Negative  tax  rate
             drivers common to this category are intangible profits in high-
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