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An Assessment Of Global Formula Apportionment
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Book Synopsis An Assessment of Global Formula Apportionment by : Ruud A. de Mooij
Download or read book An Assessment of Global Formula Apportionment written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2019-10-11 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis An Assessment of Global Formula Apportionment by : Ruud A. de Mooij
Download or read book An Assessment of Global Formula Apportionment written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2019-10-11 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Corporate Income Taxes under Pressure by : Ruud A. de Mooij
Download or read book Corporate Income Taxes under Pressure written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-26 with total page 388 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Tax and Technology by : Annika Streicher
Download or read book Tax and Technology written by Annika Streicher and published by Linde Verlag GmbH. This book was released on 2023-10-13 with total page 533 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Tax by Design for the Netherlands by : Sijbren Cnossen
Download or read book Tax by Design for the Netherlands written by Sijbren Cnossen and published by Oxford University Press. This book was released on 2021-12-16 with total page 450 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Exploring Residual Profit Allocation by : Sebastian Beer
Download or read book Exploring Residual Profit Allocation written by Sebastian Beer and published by International Monetary Fund. This book was released on 2020-02-28 with total page 51 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Taxing Multinationals in Europe by : Ernesto Crivelli
Download or read book Taxing Multinationals in Europe written by Ernesto Crivelli and published by International Monetary Fund. This book was released on 2021-05-25 with total page 61 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Tax Transfer Pricing by : Andrea Musselli
Download or read book Tax Transfer Pricing written by Andrea Musselli and published by Gruppo 24 Ore. This book was released on 2022-09-15T00:00:00+02:00 with total page 446 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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 13 :1513540076 Total Pages :67 pages Book Rating :4.5/5 (135 download)
Book Synopsis Malta by : International Monetary Fund. European Dept.
Download or read book Malta written by International Monetary Fund. European Dept. and published by International Monetary Fund. This book was released on 2020-04-10 with total page 67 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Book Synopsis Tec(h)tonic Shifts: Taxing the “Digital Economy” by : Aqib Aslam
Download or read book Tec(h)tonic Shifts: Taxing the “Digital Economy” written by Aqib Aslam and published by International Monetary Fund. This book was released on 2020-05-29 with total page 81 pages. Available in PDF, EPUB and Kindle. Book excerpt: The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.
Book Synopsis Excess Profit Taxes: Historical Perspective and Contemporary Relevance by : Mr. Shafik Hebous
Download or read book Excess Profit Taxes: Historical Perspective and Contemporary Relevance written by Mr. Shafik Hebous and published by International Monetary Fund. This book was released on 2022-09-16 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper discusses the design of excess profits taxes (EPTs) that gained renewed interest following the COVID-19 outbreak and the recent surge in energy prices. EPTs can be designed as an efficient tax only falling on economic rent, like an allowance for corporate capital, and drawing some parallels with current proposals for reforming multinationals’ taxation. EPTs can be permanent or temporary as an add-on to the corporate income tax to support revenue during an adverse shock episode. The latter reflects experiences with EPTs during and after the World Wars. Different from that era, though, profit shifting is now a challenge. Estimation using firm-level data suggest that, at present, locations of excess profit across countries are consistent with profit shifting practices by multinationals. Destination-based EPTs can address this concern. Estimates suggest that a 10 percent EPT on the globally consolidated accounts of multinationals (on top of the current corporate income tax), with the EPT base being allocated using sales, raises global revenue by 16 percent of corporate income tax revenues. The analysis suggests that international coordination would be desirable to mitigate the risks of profit shifting and tax competition. Eventually, EPTs could mark an evolution of corporate taxation toward a non-distortionary rent tax.
Book Synopsis Digitalization and Taxation in Asia by : Ms. Era Dabla-Norris
Download or read book Digitalization and Taxation in Asia written by Ms. Era Dabla-Norris and published by International Monetary Fund. This book was released on 2021-09-14 with total page 75 pages. Available in PDF, EPUB and Kindle. Book excerpt: Digitalization in Asia is pervasive, unique, and growing. It stands out by its sheer scale, with internet users far exceeding numbers in other regions. This facilitates e-commerce in markets that are large by international standards, supported by innovative payment systems and featuring major corporate players, including a number of large, home-grown, highly digitalized businesses (tech giants) that rival US multinational enterprises (MNEs) in size. Opportunity for future growth exists, as a significant population share remains unconnected.
Download or read book Catching Capital written by Peter Dietsch and published by Oxford University Press, USA. This book was released on 2015 with total page 279 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition draws into question political economic life as we know it. It undermines the fiscal autonomy of states and contributes to rising income inequalities. This book develops a normative and institutional framework to regulate tax competition. Importantly, the author shows that the proposed regulation compromises neither efficiency nor sovereignty.
Author :International Monetary Fund Publisher :International Monetary Fund ISBN 13 :1513598783 Total Pages :124 pages Book Rating :4.5/5 (135 download)
Book Synopsis Fiscal Monitor, April 2022 by : International Monetary Fund
Download or read book Fiscal Monitor, April 2022 written by International Monetary Fund and published by International Monetary Fund. This book was released on 2022-04-20 with total page 124 pages. Available in PDF, EPUB and Kindle. Book excerpt: Chapter 1 discusses how fiscal policy operates amid a sharp rise in uncertainty caused by the war in Ukraine. Chapter 2 discusses how international coordination on tax matters can support revenue, inclusion, tax transparency, and greener economies.
Book Synopsis Corporate Taxation in the Global Economy by : International Monetary Fund. Fiscal Affairs Dept.
Download or read book Corporate Taxation in the Global Economy written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2019-03-10 with total page 91 pages. Available in PDF, EPUB and Kindle. Book excerpt: The policy paper Corporate Taxation in the Global Economy stresses the need to maintain and build on the progress in international cooperation on tax matters that has been achieved in recent years, and in some respects now appears under stress. With special attention to the circumstances of developing countries, the paper identifies and discusses various options currently under discussion for the international tax system to ensure that countries, and in particular low-income countries, can continue to collect corporate tax revenues from multinational activities.
Book Synopsis Global Tax Fairness by : Thomas Pogge
Download or read book Global Tax Fairness written by Thomas Pogge and published by Oxford University Press. This book was released on 2016-02-04 with total page 371 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses sixteen different reform proposals that are urgently needed to correct the fault lines in the international tax system as it exists today, and which deprive both developing and developed countries of critical tax resources. It offers clear and concrete ideas on how the reforms can be achieved and why they are important for a more just and equitable global system to prevail. The key to reducing the tax gap and consequent human rights deficit in poor countries is global financial transparency. Such transparency is essential to curbing illicit financial flows that drain less developed countries of capital and tax revenues, and are an impediment to sustainable development. A major break-through for financial transparency is now within reach. The policy reforms outlined in this book not only advance tax justice but also protect human rights by curtailing illegal activity and making available more resources for development. While the reforms are realistic they require both political and an informed and engaged civil society that can put pressure on governments and policy makers to act.
Book Synopsis Regulating Global Corporate Capitalism by : Sol Picciotto
Download or read book Regulating Global Corporate Capitalism written by Sol Picciotto and published by Cambridge University Press. This book was released on 2011-05-12 with total page 603 pages. Available in PDF, EPUB and Kindle. Book excerpt: This analysis of how multi-level networked governance has superseded the liberal system of interdependent states focuses on the role of law in mediating power and shows how lawyers have shaped the main features of capitalism, especially the transnational corporation. It covers the main institutions regulating the world economy, including the World Bank, the IMF, the WTO and a myriad of other bodies, and introduces the reader to key regulatory arenas: corporate governance, competition policy, investment protection, anti-corruption rules, corporate codes and corporate liability, international taxation, avoidance and evasion and the campaign to combat them, the offshore finance system, international financial regulation and its contribution to the financial crisis, trade rules and their interaction with standards especially for food safety and environmental protection, the regulation of key services (telecommunications and finance), intellectual property and the tensions between exclusive private rights and emergent forms of common and collective property in knowledge.
