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審計人員之產業專精與客戶租稅規避：中國實證研究
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1. Introduction
Corporate tax avoidance is one of the most important regulatory issues that always attract
concerns from tax authorities and media. Especially recently, several large American
multinationals were investigated because of suspected tax evasion, making tax avoidance the
focus of regulation. In September 2012, the U.S. Senate Permanent Subcommittee on
Investigations accused Microsoft of evading $4.5 billion in taxes through bait-and-switch
selling with foreign subsidiaries in 2009-2012. Under the exceptions of short term loans in
related laws, Hewlett-Packard exempted billions of dollars in taxes through intra-group loans.
In May 2013, Apple was accused of evading $12.5 billion dollars via foreign operations and
overseas joint ventures in the past two years. Besides, a number of multinationals were
accused by the UK government of reallocating their profits to tax havens. For example,
Facebook shifted most of its income to Ireland where the tax burden is lower. Google and
Starbucks also have their own tax havens, such as Bermuda and the Cayman islands, and
engaged in profit-shifting activities in order to minimize their tax burdens.
Corporate tax planning may not be illegal, but some aggressive tax planning for the
purpose of tax avoidance and tax evasion are illegal tax schemes. While lawful tax planning may
be a value-maximizing activity that transfers wealth from the state to corporate shareholders,
aggressive tax planning (such as tax avoidance and tax evasion) may adversely affect the
allocation of tax resources and damage the interests of shareholders via increasing corporate risk
or facilitating managerial opportunism, such as earnings manipulation and outright resource
diversion (Chen, Chen, Cheng, and Shevlin, 2010; Desai and Dharmapala, 2009).
Although prior research has investigated the level and method of tax avoidance (e.g.,
Rego, 2003; Dyreng, Hanlon, and Maydew, 2008), many of the determinants of firms’ tax
avoidance remain unclear, and evidence on the association between external audit firm’s
industry expertise and tax avoidance is scarce. In fact, it is important to examine the role
external audit firms play in corporate tax avoidance, since external audit firms can influence
clients’ tax avoidance through at least two ways. First, external audit firms constrain tax
avoidance through auditing financial statements. Second, these firms help clients reduce tax
through providing tax services. The second way has a direct impact on the level of tax
avoidance and has attracted authorities’ attention since the 1990s. In the 1990s, malicious tax
evasion is prevalent in America. All the Big 5 audit firms
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were involved to varying degrees.
1 The Big 5 means KPMG, Ernst & Young, Deloitte & Touche, Price Waterhouse Coopers and Arthur
Anderson.