Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle

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Author :
Publisher : Kluwer Law International B.V.
ISBN 13 : 940350644X
Total Pages : 254 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle by : Eva Escribano

Download or read book Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle written by Eva Escribano and published by Kluwer Law International B.V.. This book was released on 2019-05-10 with total page 254 pages. Available in PDF, EPUB and Kindle. Book excerpt: Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle intends to demonstrate that the profit shifting phenomenon (i.e., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested “presumptive benefit principle” so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States. This PhD thesis obtained the prestigious European Academic Tax Thesis Award 2018 granted by the European Commission and the European Association of Tax Law Professors. What’s in this book: This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavors to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm’s-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the “presumptive benefit principle”) that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment. How this will help you: With its case study (based on the Apple group) empirically demonstrating the existence of the profit shifting phenomenon, its clearly documented exposure of the reasons why traditional corporate income tax regimes systematically give rise to these outcomes, its new tax policy guideline and its proposals for reform, this book makes a significant contribution to current tax policy discussions concerning corporate income taxation in cross-border scenarios. It will be warmly welcomed by all concerned—policymakers, scholars, practitioners—with the greatest tax policy challenges that corporate income taxation is facing in the contemporary world.

Statistics of Income

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Author :
Publisher :
ISBN 13 :
Total Pages : 174 pages
Book Rating : 4.3/5 ( download)

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Book Synopsis Statistics of Income by :

Download or read book Statistics of Income written by and published by . This book was released on 1980 with total page 174 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Corporate Tax Law

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Author :
Publisher : Cambridge University Press
ISBN 13 : 1107033535
Total Pages : 651 pages
Book Rating : 4.1/5 (7 download)

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Book Synopsis Corporate Tax Law by : Peter Harris

Download or read book Corporate Tax Law written by Peter Harris and published by Cambridge University Press. This book was released on 2013-03-07 with total page 651 pages. Available in PDF, EPUB and Kindle. Book excerpt: A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.

OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax

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Publisher : OECD Publishing
ISBN 13 : 9264038124
Total Pages : 174 pages
Book Rating : 4.2/5 (64 download)

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Book Synopsis OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax by : OECD

Download or read book OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax written by OECD and published by OECD Publishing. This book was released on 2007-11-13 with total page 174 pages. Available in PDF, EPUB and Kindle. Book excerpt: Presents the recent trends in the taxation of corporate income in OECD countries, discusses the main drivers of corporate income tax reform and evaluates the gains of fundamental corporate tax reform.

Tax Policy and the Economy

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Author :
Publisher :
ISBN 13 :
Total Pages : 200 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Tax Policy and the Economy by :

Download or read book Tax Policy and the Economy written by and published by . This book was released on 1993 with total page 200 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Fundamentals of Corporate Taxation

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Author :
Publisher : West Publishing Company
ISBN 13 :
Total Pages : 84 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Fundamentals of Corporate Taxation by : Stephen A. Lind

Download or read book Fundamentals of Corporate Taxation written by Stephen A. Lind and published by West Publishing Company. This book was released on 1997 with total page 84 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Core Tax Legislation and Study Guide 2022

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Publisher : Cambridge University Press
ISBN 13 : 1009154265
Total Pages : 1599 pages
Book Rating : 4.0/5 (91 download)

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Book Synopsis Core Tax Legislation and Study Guide 2022 by : Stephen Barkoczy

Download or read book Core Tax Legislation and Study Guide 2022 written by Stephen Barkoczy and published by Cambridge University Press. This book was released on 2022-01-12 with total page 1599 pages. Available in PDF, EPUB and Kindle. Book excerpt: Core Taxation Legislation and Study Guide 2022 provides curated extracts of tax legislation as well as guidance on study skills.

Tax and Corporate Governance

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Publisher : Springer Science & Business Media
ISBN 13 : 3540772766
Total Pages : 423 pages
Book Rating : 4.5/5 (47 download)

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Book Synopsis Tax and Corporate Governance by : Wolfgang Schön

Download or read book Tax and Corporate Governance written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2008-03-12 with total page 423 pages. Available in PDF, EPUB and Kindle. Book excerpt: Academic research shows that well-known principal-agent and capital market problems are strongly influenced by tax considerations. Against this background, this volume is the first to present a fully-fledged overview of the interdependence of tax and corporate governance. Not only the basic political, legal and economic questions but also major topics like income measurement, shareholding structures, corporate social responsibility and tax shelter disclosure are covered.

Tax By Design

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Publisher : Oxford University Press
ISBN 13 : 0199553742
Total Pages : 552 pages
Book Rating : 4.1/5 (995 download)

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Book Synopsis Tax By Design by : Stuart Adam

Download or read book Tax By Design written by Stuart Adam and published by Oxford University Press. This book was released on 2011-09 with total page 552 pages. Available in PDF, EPUB and Kindle. Book excerpt: Based on the findings of a commission chaired by James Mirrlees, this volume presents a coherent picture of tax reform whose aim is to identify the characteristics of a good tax system for any open developed economy, assess the extent to which the UK tax system conforms to these ideals, and recommend how it might be reformed in that direction.

Corporate Tax Reform

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Author :
Publisher : Createspace Independent Publishing Platform
ISBN 13 : 9781978091900
Total Pages : 66 pages
Book Rating : 4.0/5 (919 download)

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Book Synopsis Corporate Tax Reform by : Jane Gravelle

Download or read book Corporate Tax Reform written by Jane Gravelle and published by Createspace Independent Publishing Platform. This book was released on 2017-10-10 with total page 66 pages. Available in PDF, EPUB and Kindle. Book excerpt: Interest in corporate tax reform that lowers the rate and broadens the base has developed in the past several years. Some discussions by economists in opinion pieces have suggested there is an urgent need to lower the corporate tax rate, but not necessarily to broaden the tax base, an approach that presents some difficulties given current budget pressures. Others see the corporate tax as a potential source of revenue. Arguments for lowering the corporate tax rate include the traditional concerns about economic distortions arising from the corporate tax and newer concerns arising from the increasingly global nature of the economy. Some claims have been made that lowering the corporate tax rate would raise revenue because of the behavioral responses, an effect that is linked to an open economy. Although the corporate tax has generally been viewed as contributing to a more progressive tax system because the burden falls on capital income and thus on higher-income individuals, claims have also been made that the burden falls not on owners of capital, but on labor income. The analysis in this report suggests that many of the concerns expressed about the corporate tax are not supported by empirical evidence. Claims that behavioral responses could cause revenues to rise if rates were cut do not hold up on either a theoretical or an empirical basis. Studies that purport to show a revenue-maximizing corporate tax rate of 30% (a rate lower than the current statutory tax rate) contain econometric errors that lead to biased and inconsistent results; when those problems are corrected the results disappear. Cross-country studies to provide direct evidence showing that the burden of the corporate tax actually falls on labor yield unreasonable results and prove to suffer from econometric flaws that also lead to a disappearance of the results when corrected, in those cases where data were obtained and the results replicated. Many studies that have been cited are not relevant to the United States because they reflect wage bargaining approaches and unions have virtually disappeared from the private sector in the United States. Overall, the evidence suggests that the tax is largely borne by capital. Similarly, claims that high U.S. tax rates will create problems for the United States in a global economy suffer from a misrepresentation of the U.S. tax rate compared with other countries and are less important when capital is imperfectly mobile, as it appears to be. Although these new arguments appear to rely on questionable methods, the traditional concerns about the corporate tax appear valid. While an argument may be made that the tax is still needed as a backstop to individual tax collections, it does result in some economic distortions. These economic distortions, however, have declined substantially over time as corporate rates and shares of output have fallen. Moreover, it is difficult to lower the corporate tax without creating a way of sheltering individual income given the low tax rates on dividends and capital gains. A number of revenue-neutral changes are available that could reduce these distortions, allow for a lower corporate statutory tax rate, and lead to a more efficient corporate tax system. These changes include base broadening, reducing the benefits of debt finance through inflation indexing, taxing large pass-through firms as corporations, and reducing the tax at the firm level offset by an increase at the individual level. Nevertheless, the scope for reducing the tax rate in a revenue-neutral way may be limited.

The Effects of Taxation on Multinational Corporations

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Author :
Publisher : University of Chicago Press
ISBN 13 : 0226241874
Total Pages : 338 pages
Book Rating : 4.2/5 (262 download)

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Book Synopsis The Effects of Taxation on Multinational Corporations by : Martin Feldstein

Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.

A Comparative Look at Regulation of Corporate Tax Avoidance

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Publisher : Springer Science & Business Media
ISBN 13 : 9400723423
Total Pages : 387 pages
Book Rating : 4.4/5 (7 download)

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Book Synopsis A Comparative Look at Regulation of Corporate Tax Avoidance by : Karen B. Brown

Download or read book A Comparative Look at Regulation of Corporate Tax Avoidance written by Karen B. Brown and published by Springer Science & Business Media. This book was released on 2011-12-09 with total page 387 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume provides a fascinating look at the anti-tax avoidance strategies employed by more than fifteen countries in eastern and western Europe, Canada, the Pacific Rim, Asia, Africa, and the United States. It surveys the similarities and differences in anti-avoidance regimes and contains detailed chapters for each country surveying the moral and legal dimensions of the problem. The proliferation of tax avoidance schemes in recent years signals the global dimensions of a problem presenting a serious challenge to the effective administration of tax laws. Tax avoidance involves unacceptable manipulation of the law to obtain a tax advantage. These transactions support wasteful behavior in which corporations enter into elaborate, circuitous arrangements solely to minimize tax liability. It frustrates the ability of governments to collect sufficient revenue to provide essential public goods and services. Avoidance of duly enacted provisions (or manipulation to secure tax benefits unintended by the legislature) poses a threat to the effective operation of a free society for the benefit of a small group of members who seek the privilege of shifting their tax burden onto others merely to compete in the world of commerce. In a world in which world treasuries struggle for the resources to battle terrorist threats and to secure a decent standard of living for constituents tax avoidance can bring economies close to the edge of sustainability. As tax avoidance is one of the top concerns of most nations, the importance of this work cannot be overstated.

The Great American Jobs Scam

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Publisher : Berrett-Koehler Publishers
ISBN 13 : 1609943511
Total Pages : 299 pages
Book Rating : 4.6/5 (99 download)

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Book Synopsis The Great American Jobs Scam by : Greg LeRoy

Download or read book The Great American Jobs Scam written by Greg LeRoy and published by Berrett-Koehler Publishers. This book was released on 2005-07-21 with total page 299 pages. Available in PDF, EPUB and Kindle. Book excerpt: For the past 20 years, corporations have been receiving huge tax breaks and subsidies in the name of "jobs, jobs, jobs." But, as Greg LeRoy demonstrates in this important new book, it's become a costly scam. Playing states and communities off against each other in a bidding war for jobs, corporations reduce their taxes to next-to-nothing and win subsidy packages that routinely exceed $100,000 per job. But the subsidies come with few strings attached. So companies feel free to provide fewer jobs, or none at all, or even outsource and lay people off. They are also free to pay poverty wages without health care or other benefits. All too often, communities lose twice. They lose jobs--or gain jobs so low-paying they do nothing to help the community--and lose revenue due to the huge corporate tax breaks. That means fewer resources for maintaining schools, public services, and infrastructure. In the end, the local governments that were hoping for economic revitalization are actually worse off. They're forced to raise taxes on struggling small businesses and working families, or reduce services, or both. Greg LeRoy uses up-to-the-minute examples, naming names--including Wal-Mart, Raytheon, Fidelity, Bank of America, Dell, and Boeing--to reveal how the process works. He shows how carefully corporations orchestrate the bidding wars between states and communities. He exposes shadowy "site location consultants" who play both sides against the middle, and he dissects government and corporate mumbo-jumbo with plain talk. The book concludes by offering common-sense reforms that will give taxpayers powerful new tools to deter future abuses and redirect taxpayer investments in ways that will really pay off.

Risk and Return for Regulated Industries

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Publisher : Academic Press
ISBN 13 : 0128125888
Total Pages : 362 pages
Book Rating : 4.1/5 (281 download)

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Book Synopsis Risk and Return for Regulated Industries by : Bente Villadsen

Download or read book Risk and Return for Regulated Industries written by Bente Villadsen and published by Academic Press. This book was released on 2017-04-27 with total page 362 pages. Available in PDF, EPUB and Kindle. Book excerpt: Risk and Return for Regulated Industries provides a much-needed, comprehensive review of how cost of capital risk arises and can be measured, how the special risks regulated industries face affect fair return, and the challenges that regulated industries are likely to face in the future. Rather than following the trend of broad industry introductions or textbook style reviews of utility finance, it covers the topics of most interest to regulators, regulated companies, regulatory lawyers, and rate-of-return analysts in all countries. Accordingly, the book also includes case studies about various countries and discussions of the lessons international regulatory procedures can offer. - Presents a unified treatment of the regulatory principles and practices used to assess the required return on capital - Addresses current practices before exploring the ways methods play out in practice, including irregularities, shortcomings, and concerns for the future - Focuses on developed economies instead of providing a comprehensive global reviews - Foreword by Stewart C. Myers

CBT Corporate Tax Ranking 2012

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Publisher :
ISBN 13 : 9780955935046
Total Pages : 36 pages
Book Rating : 4.9/5 (35 download)

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Book Synopsis CBT Corporate Tax Ranking 2012 by : Katarzyna Bilicka

Download or read book CBT Corporate Tax Ranking 2012 written by Katarzyna Bilicka and published by . This book was released on 2012 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Corporate Tax Study

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Publisher :
ISBN 13 :
Total Pages : 122 pages
Book Rating : 4.3/5 (243 download)

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Book Synopsis Corporate Tax Study by :

Download or read book Corporate Tax Study written by and published by . This book was released on 1983 with total page 122 pages. Available in PDF, EPUB and Kindle. Book excerpt:

Research Handbook on Corporate Taxation

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Author :
Publisher : Edward Elgar Publishing
ISBN 13 : 1803923113
Total Pages : 475 pages
Book Rating : 4.8/5 (39 download)

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Book Synopsis Research Handbook on Corporate Taxation by : Reuven S. Avi-Yonah

Download or read book Research Handbook on Corporate Taxation written by Reuven S. Avi-Yonah and published by Edward Elgar Publishing. This book was released on 2023-08-14 with total page 475 pages. Available in PDF, EPUB and Kindle. Book excerpt: Encapsulating the multitude of challenges faced by the international corporate tax regime, this timely Research Handbook provides an in-depth comparative legal analysis of corporate income tax as it is practiced across the world. With a variety of paths to reform proposed throughout, it will prove an invigorating read for tax scholars working on taxation and tax law as well as for tax practitioners and those in fiscal policy seeking ways to improve, or navigate, the current state of affairs in international corporate tax law.