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Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513516256
Category : Business & Economics
Languages : en
Pages : 41
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Book Description
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative to the current international tax regime that is based on separate accounting. It highlights major advantages, such as the elimination of profit shifting within multinational groups; and it discusses new distortions and the impact on tax competition. The analysis exploits different datasets to assess the direct revenue implications for individual countries under alternative formulas. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in investment hubs (i.e. countries with a disproportionate ratio of foreign direct investment to GDP), while several large advanced countries are likely to gain. Developing countries gain most likely if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination.
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513516256
Category : Business & Economics
Languages : en
Pages : 41
Get Book Here
Book Description
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative to the current international tax regime that is based on separate accounting. It highlights major advantages, such as the elimination of profit shifting within multinational groups; and it discusses new distortions and the impact on tax competition. The analysis exploits different datasets to assess the direct revenue implications for individual countries under alternative formulas. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in investment hubs (i.e. countries with a disproportionate ratio of foreign direct investment to GDP), while several large advanced countries are likely to gain. Developing countries gain most likely if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination.
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513517201
Category : Business & Economics
Languages : en
Pages : 41
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Book Description
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative to the current international tax regime that is based on separate accounting. It highlights major advantages, such as the elimination of profit shifting within multinational groups; and it discusses new distortions and the impact on tax competition. The analysis exploits different datasets to assess the direct revenue implications for individual countries under alternative formulas. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in investment hubs (i.e. countries with a disproportionate ratio of foreign direct investment to GDP), while several large advanced countries are likely to gain. Developing countries gain most likely if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination.
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513511777
Category : Business & Economics
Languages : en
Pages : 388
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Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Author: Annika Streicher
Publisher: Linde Verlag GmbH
ISBN: 3709413001
Category : Law
Languages : en
Pages : 533
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Book Description
The challenges and opportunities of new technologies in the tax field Technological developments induced major reforms in the regulatory international and domestic tax landscapes as well as in the developments in the use of technology by tax administrations and taxpayers. New technology, especially the innovations in virtual asset-light cross-border business organizations, data analytics, service and process automation, on one hand, disrupted the well-established legal tax principles and rules and, on the other, stimulated informed data-driven and structured solutions in tax compliance. Technological advances affected nearly every area and each aspect of taxation: Direct tax regulations, indirect tax law, and tax procedures including tax compliance, and tax control functions. International organizations such as the Organization for Economic Co-operation and Development (OECD), the United Nations (UN), and the European Commission as a supranational organization fostered critical legislative reforms and proposals among which are the OECD Two-Pillar Solution to Address the Tax Challenges Arising from Digitalisation of the Economy, Article 12B of the UN Model Tax Convention to tax automated digital services, new rules for tracing transfers of crypto-assets in the EU, as well as the EU ́s VAT e-commerce package and "VAT in the Digital Age" package. While these proposals aim to address a wide range of the benefits and challenges of Economy 4.0, certain questions arise concerning the consistency of the legislative developments with their initial objectives, the appropriateness of the legal form for the economic substance of the regulated relations for the effectiveness of the regulations as well as their coherence. This volume contains a collection of scientific chapters on the general topic "Tax and Technology" that were successfully completed by the 2022/2023 LL.M. graduates of the Institute for Austrian and International Tax Law, WU. The volume is divided into three parts that contain the contributions dealing with the impact of the technology on international tax law, indirect tax law, and procedural law. Each chapter provides an in-depth analysis of a unique research question aiming to innovatively contribute to the current debate and develop a practical approach for implementing the findings.
Author: Sijbren Cnossen
Publisher: Oxford University Press
ISBN: 0192667483
Category : Business & Economics
Languages : en
Pages : 450
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Book Description
The Dutch tax system distorts economic decisions, treats equal economic positions unequally for tax purposes, and is extraordinarily complex. Following in the footsteps of the Mirrlees Review, prominent economists from academia and the policy arena, at home and abroad, provide independent, evidence-based analyses of the system's shortcomings, as well as detailed proposals for reform. Tax by Design for the Netherlands spans the whole spectrum of taxes on labor and capital income, profits, consumption, wealth, inheritance, and charges to correct for market and individual failure, including the environment.
Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 1513528327
Category : Business & Economics
Languages : en
Pages : 51
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Book Description
Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.
Author: Ernesto Crivelli
Publisher: International Monetary Fund
ISBN: 1513570765
Category : Business & Economics
Languages : en
Pages : 61
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Book Description
This paper aims to contribute to the European policy debate on corporate income tax reform in three ways. First, it takes a step back to review the performance of the CIT in Europe over the past several decades and the important role played by MNEs in European economies. Second, it analyses corporate tax spillovers in Europe with a focus on the channels and magnitudes of both profit shifting and CIT competition. Third, the paper examines the progress made in European CIT coordination and discusses reforms to strengthen the harmonization of corporate tax policies, in order to effectively reduce both tax competition and profit shifting.
Author: Andrea Musselli
Publisher: Gruppo 24 Ore
ISBN:
Category : Business & Economics
Languages : en
Pages : 446
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Book Description
The book pays attention to the tax treatment of transfer pricing in a single perspective of analysis since the most important principles (the arm’s length -ALP- i.e. conditions that independent parties would share, and the sale country) are agreed worldwide. They must be applied in the same way regardless of the economic sector or industry. A country survey overlooks the most important issue of the fiscal problem, that is, the ability to project a unitary policy in compliance with the ALP (or with the sale country principle) and that should be audited by one sole (only theoretically) existing tax authority. The practical part and examples disclose how rules should be/have been applied, how legal proceedings can arise/arose regarding their application , how they were decided if litigation truly occurred, and finally the author’s motivated opinion with special focus on which is “the breaking point” of a specific analysis. The term “breaking point” is used to explain which can be the factual and/or the interpretative change that is able to modify such analysis and thus the solution. Extract from the preface of prof. Reuven Avi-Yonah: “this book is a must read for any serious student of the topic and an important contribution to understanding how the ALP is applied today as well as to how it should be applied. It is an invaluable contribution and should be read widely by both tax lawyers and accountants and by tax policy makers”.
Author: International Monetary Fund. European Dept.
Publisher: International Monetary Fund
ISBN: 1513540076
Category : Business & Economics
Languages : en
Pages : 67
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Book Description
This 2020 Article IV Consultation focuses on Malta’s near and medium-term challenges and policy priorities and was prepared before coronavirus disease 2019 became a global pandemic and resulted in unprecedented strains in global trade, commodity and financial markets. Pursuing structural reforms is expected to help sustain Malta’s growth performance while promoting social inclusion. The focus should continue to be on encouraging female and elderly participation in the labor market, upskilling the labor force and stimulating innovation. Moreover, to safeguard the business climate, remaining governance shortcomings should be addressed without delay, including by stepping up the fight against corruption and by increasing the efficiency of the judicial system while ensuring its independence. Improving access to affordable housing remains a key priority in support of greater inclusion. It is imperative to maintain gradual consolidation to ensure a balanced structural budget excluding proceeds from the Individual Investor Program. The IMF staff suggests continuing addressing infrastructure needs while upgrading public investment efficiency. Improve fiscal risk analysis and management.
Author: Peter Dietsch
Publisher: Oxford University Press
ISBN: 0190251522
Category : Philosophy
Languages : en
Pages : 279
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Book Description
Rich people stash away trillions of dollars in tax havens like Switzerland, the Cayman Islands, or Singapore. Multinational corporations shift their profits to low-tax jurisdictions like Ireland or Panama to avoid paying tax. Recent stories in the media about Apple, Google, Starbucks, and Fiat are just the tip of the iceberg. There is hardly any multinational today that respects not just the letter but also the spirit of tax laws. All this becomes possible due to tax competition, with countries strategically designing fiscal policy to attract capital from abroad. The loopholes in national tax regimes that tax competition generates and exploits draw into question political economic life as we presently know it. They undermine the fiscal autonomy of political communities and contribute to rising inequalities in income and wealth. Building on a careful analysis of the ethical challenges raised by a world of tax competition, this book puts forward a normative and institutional framework to regulate the practice. In short, individuals and corporations should pay tax in the jurisdictions of which they are members, where this membership can come in degrees. Moreover, the strategic tax setting of states should be limited in important ways. An International Tax Organisation (ITO) should be created to enforce the principles of tax justice. The author defends this call for reform against two important objections. First, Dietsch refutes the suggestion that regulating tax competition is inefficient. Second, he argues that regulation of this sort, rather than representing a constraint on national sovereignty, in fact turns out to be a requirement of sovereignty in a global economy. The book closes with a series of reflections on the obligations that the beneficiaries of tax competition have towards the losers both prior to any institutional reform as well as in its aftermath.
