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Tax Incentives In The Beps Era
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Book Synopsis Tax Incentives in the BEPS Era by : Madalina Cotrut
Download or read book Tax Incentives in the BEPS Era written by Madalina Cotrut and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: Recent tax developments aimed at mitigating the possibilities of base erosion and profit shifting are expected to increase the importance and popularity of tax incentives. This is due to the fact that states will want to remain competitive on the international stage and multinational enterprises will look for other opportunities to minimize their tax liabilities.0This book seeks to answer the following essential questions, from both a practical and an academic perspective:0- Will tax incentives be the 21st century tool for tax planning structures?0- Will states need to introduce more tax incentives in the future in order to be more competitive?0- What are the effects of the anti-abuse measures adopted by the EU Member States and recommended by the OECD on tax incentives?0- What are the challenges of securing the use of tax incentives?0- What new tax policy challenges will tax incentives bring about? 00This book answers these questions by analysing selected tax incentives that are commonly promoted by both developed and developing states, particularly those tax incentives that are of relevance to corporate income taxation.
Book Synopsis Two Cheers for the Foreign Tax Credit, Even in the BEPS Era by : J. Clifton Fleming
Download or read book Two Cheers for the Foreign Tax Credit, Even in the BEPS Era written by J. Clifton Fleming and published by . This book was released on 2017 with total page 55 pages. Available in PDF, EPUB and Kindle. Book excerpt: Reform of the U.S. international income taxation system has been a hotly debated topic for many years. The principal competing alternatives are a territorial or exemption system and a worldwide system. For reasons summarized in this article, we favor worldwide taxation if it is real worldwide taxation - i.e., a non-deferred U.S. tax is imposed on all foreign income of U.S. residents at the time the income in earned. This approach is not acceptable, however, unless the resulting double taxation is alleviated. The longstanding U.S. approach for handling the international double taxation problem is a foreign tax credit limited to the U.S. levy on the taxpayer's foreign income. Indeed, the foreign tax credit is an essential element of the case for worldwide taxation. Moreover, territorial systems often apply worldwide taxation with a foreign tax credit to all income of resident individuals plus the passive income and tax haven income of resident corporations. Thus, the foreign tax credit is actually an important feature of many territorial systems. The foreign tax credit has, however, been subjected to sharp criticisms and Professor Daniel Shaviro has recently proposed replacing the credit with a combination of a deduction for foreign taxes and a reduced U.S. tax rate on foreign income. In this article, we respond to the criticisms and argue that the foreign tax credit is a robust and effective device. Furthermore, we respectfully explain why Professor Shaviro's proposal is not an adequate substitute. We also explore an overlooked aspect of the foreign tax credit - its role as an allocator of the international tax base between residence and source countries - and we explain the credit's effectiveness in carrying out this role. Nevertheless, we point out that the credit merits only two cheers because it goes beyond the requirements of the ability-to-pay principle that underlies use of an income base for imposing tax (instead of a consumption base). On balance, however, the credit is the preferred approach for mitigating international double taxation of income.
Author : Publisher : ISBN 13 :9041199918 Total Pages :490 pages Book Rating :4.0/5 (411 download)
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Book Synopsis Tax Sovereignty in the BEPS Era by : Sergio André Rocha
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International. This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: BEPS and the power to tax / Allison Christians -- Tax sovereignty and digital economy in post-BEPS times / Ramon Tomazela Santos & Sergio André Rocha -- Justification and implementation of the international allocation of taxing rights: can we take one thing at a time? / Luís Eduardo Schoueri & Ricardo André Galendi Júnior -- An essay on BEPS / Sovereignty / and Taxation / Yariv Brauner -- Evaluating BEPS / Reuven S. Avi-Yonah & Haiyan Xu -- Jurisdictional excesses in BEPS' times: national appropriation of an enhanced global tax basis / Guillermo O. Teijeiro -- Taxing the consumption of digital goods / Aleksandra Bal -- The birth of a new international tax framework and the role of developing countries / Natalia Quiñones -- The other side of BEPS: "imperial taxation" and "international tax imperialism" / Sergio André Rocha -- Country-by-country over-reporting? national sovereignty, international tax transparency, and the inclusive framework on BEPS / Romero J.S. Tavares -- How are we doing with BEPS recommendations in the EU? / Tomas Balco & Xeniya Yeroshenko -- U.S. tax sovereignty and the BEPS project / Tracy A. Kaye
Book Synopsis International Tax Structures in the BEPS Era by : Madalina Cotrut
Download or read book International Tax Structures in the BEPS Era written by Madalina Cotrut and published by . This book was released on 2015 with total page 324 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax planning structures used by some MNEs have become the bane of policymakers nowadays, at the OECD as well as the EU level, since recent statistics revealed public budgets were deprived of billions of euros. 0Within the context of recent developments in the tax arena, this book examines the anti-abuse measures that already exist in various countries and scrutinizes the effectiveness of these measures in countering aggressive tax structures. This work can be considered complementary to the reports issued or to be issued by the OECD, and to the recent activity at the EU level, as it provides an in-depth analysis of what is already happening in practice in various countries when they encounter abusive tax structures. It also highlights the challenges implicit in the recommended measures in the draft reports issued by the OECD up until 1 May 2015, with some exceptions. The book provides the reader with an analysis of the most common strategies against tax avoidance; the key concepts in international tax structuring, such as the use of permanent establishments and the exploitation of transfer pricing rules; and the intricacies of anti-abuse measures that counter tax structuring schemes used for financing activities and for selected business models, specifically related to supply chain management, IP migration and exploitation, the digital economy and holding companies.
Book Synopsis Tax Sovereignty in the BEPS Era by : Sergio André Rocha
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Book Synopsis U.S. Investment Since the Tax Cuts and Jobs Act of 2017 by : Emanuel Kopp
Download or read book U.S. Investment Since the Tax Cuts and Jobs Act of 2017 written by Emanuel Kopp and published by International Monetary Fund. This book was released on 2019-05-31 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: There is no consensus on how strongly the Tax Cuts and Jobs Act (TCJA) has stimulated U.S. private fixed investment. Some argue that the business tax provisions spurred investment by cutting the cost of capital. Others see the TCJA primarily as a windfall for shareholders. We find that U.S. business investment since 2017 has grown strongly compared to pre-TCJA forecasts and that the overriding factor driving it has been the strength of expected aggregate demand. Investment has, so far, fallen short of predictions based on the postwar relation with tax cuts. Model simulations and firm-level data suggest that much of this weaker response reflects a lower sensitivity of investment to tax policy changes in the current environment of greater corporate market power. Economic policy uncertainty in 2018 played a relatively small role in dampening investment growth.
Download or read book Taxing Wages 2021 written by OECD and published by OECD Publishing. This book was released on 2021-04-29 with total page 651 pages. Available in PDF, EPUB and Kindle. Book excerpt: This annual publication provides details of taxes paid on wages in OECD countries. It covers personal income taxes and social security contributions paid by employees, social security contributions and payroll taxes paid by employers, and cash benefits received by workers. Taxing Wages 2021 includes a special feature entitled: “Impact of COVID-19 on the Tax Wedge in OECD Countries”.
Book Synopsis Tax Incentives and Foreign Direct Investment by :
Download or read book Tax Incentives and Foreign Direct Investment written by and published by . This book was released on 2000 with total page 169 pages. Available in PDF, EPUB and Kindle. Book excerpt: Foreign direct investment (FDI) is increasingly being recognized as an important factor in the economic development of countries. This study contains a survey of tax incentive regimes in over 45 countries from all regions of the world. The analysis sheds light on other issues such as design considerations, the importance of proper administration of incentives and measures to increase the efficacy of tax incentives offered. Policy makers will find the study a useful tool in the design, implementation and administration of tax incentives.
Book Synopsis Causes, Benefits, and Risks of Business Tax Incentives by : Alexander Klemm
Download or read book Causes, Benefits, and Risks of Business Tax Incentives written by Alexander Klemm and published by INTERNATIONAL MONETARY FUND. This book was released on 2009-01-01 with total page 27 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper provides an updated overview of tax incentives for business investment. It begins by noting that tax competition is likely to be a major force driving countries' tax reforms, and discusses tax incentives as a possible response to this. This is complemented by other arguments for and against tax incentives, and by an illustrative analysis of different incentives using effective tax rates. Findings from the empirical literature on tax incentives are also presented. Based on the overview of theoretical and empirical findings, the paper then suggests a matrix of criteria to determine the usefulness of different tax incentives depending on a country's circumstances.
Book Synopsis Taxation, International Cooperation and the 2030 Sustainable Development Agenda by : Irma Johanna Mosquera Valderrama
Download or read book Taxation, International Cooperation and the 2030 Sustainable Development Agenda written by Irma Johanna Mosquera Valderrama and published by Springer Nature. This book was released on 2021-03-29 with total page 228 pages. Available in PDF, EPUB and Kindle. Book excerpt: This open access volume addresses the link between international taxation, the 2030 Sustainable Development Agenda and the medium-term revenue strategy concept. It also analyses how countries and governments can reinforce this link in current and future initiatives in international taxation, including the base erosion profit shifting project initiated by the Organization for Economic Co-operation and Development with the political mandate of the G20. It discusses the 2030 Sustainable Development Agenda that are relevant for taxation and assesses the current work done by international organizations, regional tax organizations and countries to achieve these Sustainable Development Goals. The contributions to this volume provide an interdisciplinary mix of expertise in tax law, international political economy, global governance and international relations. Through these different perspectives, this volume provides an elaborate reference and evaluation framework for multilateral cooperation on tax and development to strengthen the revenue system of developed and developing countries. This topical volume is of interest to students and researchers of the social sciences, law and economics, as well as policy makers working on taxation.
Book Synopsis Complexity and Sustainability in Megaprojects by : Franca Cantoni
Download or read book Complexity and Sustainability in Megaprojects written by Franca Cantoni and published by Springer Nature. This book was released on with total page 300 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Tax Sovereignty and the Law in the Digital and Global Economy by : Francesco Farri
Download or read book Tax Sovereignty and the Law in the Digital and Global Economy written by Francesco Farri and published by Routledge. This book was released on 2020-09-27 with total page 249 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses which is the most appropriate tax dimension to best manage the new horizons of the global and digital economy. In this perspective, the efficiency of the main models is examined and two fundamental proposals are put forth: the first one aims at a coordination of the Destination-Based approach with the role of some specific digital assets, such as user data; the second one is a framework for a possible futuristic tax phenomenon all internal to the world of the internet and not linked to traditional territorial States. The compliance of these models with the constitutional principles that western democratic systems have affirmed over time in matters of taxation is then analyzed with particular regard to legal certainty, consent to taxation and to the re-distributive function of taxes. A specific evaluation of the role of the European Union is carried out and the jurisprudence on financial interests of the Union and on State aids is analyzed and tackled in light of the Treaty on the Functioning of the European Union and of the tax sovereignty of member States. The conclusion is that the model of the organization with a general political purpose, from which modern States take their inspiration, appears unfailing for a tax project that would focus on the good and the growth of the person and of the social aggregations in which everyone lives. A model that therefore deserves to be safeguarded, although with new methods and instruments, starting from a Destination-Based Asset-Coordinated approach, in the Third Millennium. The book will be of interest to researchers and academics in international tax law, constitutional law and in political science.
Book Synopsis International Economic Law and the Challenges of the Free Zones by : Julien Chaisse
Download or read book International Economic Law and the Challenges of the Free Zones written by Julien Chaisse and published by Kluwer Law International B.V.. This book was released on 2019-05-02 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: Special economic zones (SEZs) have become a permanent feature of the world trade scene. This book, the first to provide a critical and comprehensive analysis of SEZs covering a wide spectrum of countries and regions, shows how SEZs, albeit established at the domestic level by different countries, raise multiple legal issues under international economic law. This first-rate book is the product of the Asia FDI Forum IV held in Hong Kong in 2018. Thoroughly exploring the development of the SEZ phenomenon and its players, the contributing authors (all leading economic law experts) review the issues raised by SEZs in the context of international trade law, international investment law and investment arbitration. They identify the extent to which SEZs have been coherent in their design and policymaking, in particular with regard to domestic law reforms. They address such aspects (both core themes and specific examples) as the following: investment protection in China’s SEZs; state-owned enterprises regulation; dispute settlement; under what circumstances incentives available in SEZs count as export subsidies prohibited under World Trade Organization (WTO) rules; compliance with internal market rules in European Union (EU) free zones; local populations as victims of land expropriation; Brazil’s Manaus Free Trade Zone; India’s experience with multiple SEZs; the administrative approval system in the Shanghai Free Trade Zone; economic corridors and transit routes as SEZs; ‘refugee cities’: SEZs for migrants; how China’s Supreme People’s Court serves national strategy; how foreign investors challenge free-zone regimes; impacts of the establishment of SEZs on tax revenues; SEZs and labour migration; and management models. The chapters also include insights into the new emerging generation of international investment agreements; WTO accession, transparency, and case law materials clarifying specific trade issues associated with SEZs; and new rules to protect the environment and labour rights, as well as analysis of crucially significant cases such as Goetz v. The Republic of Burundi, Lee Jong Baek v. Kyrgyzstan and Ampal-American and Others v. Egypt. With its critical and comprehensive analysis of the dynamic SEZ phenomenon across legal, economic, investment, regulatory and policy matrices – including a thorough analysis of the success factors and required policies for SEZs – this book takes a giant step towards answering the question whether SEZs fundamentally contradict norms of international law or whether SEZs have to be considered as laboratories which facilitate the implementation of international economic policies. Its careful examination of theory and practice and its approach to lessons learned from case studies will reward trade and investment officials, policymakers, diplomats, economists, lawyers, think tanks, business leaders and others interested in this ever more important area of law and economics.
Book Synopsis Customs Valuation and Transfer Pricing by : Juan Martin Jovanovich
Download or read book Customs Valuation and Transfer Pricing written by Juan Martin Jovanovich and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 216 pages. Available in PDF, EPUB and Kindle. Book excerpt: Issues of transfer pricing have come to the fore in both international tax and customs regimes. In particular, the problem of how to apply the two systems of valuation to the same transaction is of widespread concern. This well-known book, now in a fully updated second edition, is a problem-solving guide for professionals charged with valuating transactions in their client’s or company’s best interests. Through detailed examination of relevant guidelines, transfer pricing methodologies, and business realities prevailing among multinational enterprises, it offers a cogent and convincing account of how tax and customs transfer pricing regimes may be harmonized. Among other essential elements, the author discusses the following in depth: – the OECD Transfer Pricing Guidelines; – the GATT/WTO Customs Valuation Code (GVC) and other valuation rules in key jurisdictions and regional agreements; – the OECD and UN model tax conventions; – the arm’s length principle; – methods, both traditional and new, of determining whether the parties’ relationship in uenced the price; and – additions to and deductions from the customs value. This second edition discusses new developments in the eld, including a chapter on Commentary 23.1 and Case Study 14.1 of the Technical Committee on Customs Valuation of the World Customs Organization (WCO) – the rst international instruments linking transfer pricing and customs valuation. The book concludes with an analysis of the circumstances and conditions under which the introduction of transfer pricing year-end adjustments to transaction value would be consistent with Article 1 of the GVC. The book will continue to provide practitioners, customs administrations, and academics with a highly practical analysis of the intersection of transfer pricing and customs valuation. It will be welcomed by customs administrations charged with examining the acceptability of a transaction value xed between related parties and by multinational companies as a truly actionable tool they can use to optimize decision-making as it relates to transfer pricing and customs valuation in a “real world” setting.
Book Synopsis Preventing Treaty Abuse by : Daniel Blum
Download or read book Preventing Treaty Abuse written by Daniel Blum and published by Linde Verlag GmbH. This book was released on 2016-09-19 with total page 571 pages. Available in PDF, EPUB and Kindle. Book excerpt: Analysis of notion, roots und measures of treaty abuse The OECD initiative on Base Erosion and Profit Shifting has put the issue of treaty abuse and the means to counter it on top of the global political agenda. Preventing treaty abuse is therefore currently one of the most debated topics in international tax law. Diverging national legal traditions in combatting abuse both under domestic and tax treaty law have led to a globally diversified legal framework in this respect and make the OECD’s agenda to harmonize these attempts even more challenging. The aim of this book is to analyze the notion of treaty abuse, its historical roots and the measures to counter it. The book’s topics cover a wide range of both policy and legal issues. The contributions’ main focus lies onanalyzing the proposals put forward by the OECD in BEPS action items 6 and 7. In addition, this book analyzes the lessons which can be learnt from the US tax treaty policy and elaborates on the effects the intensified fight against treaty abuse will have from a Non-OECD member state perspective. Also EU law is taken into account and the question raised which impact the fundamental freedoms might have on the development of new anti-avoidance rules. Finally the relation between domestic and treaty based anti-avoidance is analyzed in great detail, identifying the methodical problems of ensuring a sound and abuse safe legal framework. With this book, the authors and editors hope to contribute to the discussion on selected issues of preventing treaty abuse and the challenges they present to policy makers, judges, tax administrations and tax advisers.
Book Synopsis Taxing Profit in a Global Economy by : Michael P. Devereux
Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.
