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Towards A Neutral Formulary Apportionment System In Regional Integration
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Book Synopsis Towards a Neutral Formulary Apportionment System in Regional Integration by : Shu-Chien Chen
Download or read book Towards a Neutral Formulary Apportionment System in Regional Integration written by Shu-Chien Chen and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 471 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.
Book Synopsis Towards a Neutral Formulary Apportionment System in Regional Integration by : Shu-Chien Chen
Download or read book Towards a Neutral Formulary Apportionment System in Regional Integration written by Shu-Chien Chen and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The traditional international tax regime faces challenges in the digital economy and is criticised for not fairly allocating taxing rights over the profits of multinational enterprises (MNEs)' cross- border economic activities. Allocating taxing rights based on value creation is an urgent reform imperative. OECD's Base Erosion and Profit Shifting (BEPS) project in 2015 is a reform effort to address this problem.Since 2021, OECD's Pillar One has established the “new” taxing rights of the market jurisdiction. OECD's Pillar One uses a formula approach to decide the profit allocation. Such development shows that “formulary apportionment” (FA) could be a feasible option for tax reform. However, the core question remains: How should a fair FA be designed to allocate taxing rights? The article especially discusses the FA system in the European Union (EU). The full text is at https://pure.eur.nl/ws/portalfiles/portal/83033157/Towards_a_neutral_formulary_apportionment.pdf.
Author :Maria Júlia Ildefonso Mendonça Publisher :Kluwer Law International B.V. ISBN 13 :9403503084 Total Pages :381 pages Book Rating :4.4/5 (35 download)
Book Synopsis International Juridical Double Taxation from an Ability-to-Pay Perspective under EU Law by : Maria Júlia Ildefonso Mendonça
Download or read book International Juridical Double Taxation from an Ability-to-Pay Perspective under EU Law written by Maria Júlia Ildefonso Mendonça and published by Kluwer Law International B.V.. This book was released on 2023-01-22 with total page 381 pages. Available in PDF, EPUB and Kindle. Book excerpt: The hurdles emerging from the parallel exercise of Member States’ tax sovereignty have been examined by the CJEU and intensely discussed by scholars. By uncovering a paradox in the CJEU’s case law, this groundbreaking book provides a constructive alternative to the deadlock created by the CJEU when ruling that international juridical double taxation, although constituting an obstacle to free movement, is not contrary to EU law. The book – the first in-depth treatment of this perspective – enables taxpayers facing international juridical double taxation to understand how their ability to pay is protected under EU law and the limitations that protection faces. Every aspect of the matter is rigorously examined, including the following: important differences between the traditional notion of double taxation and the current definition under Council Directive 2017/1852; legal means and methods designed to eliminate international juridical double taxation and the policies underlying them; freedoms of movement as prohibitions that limit the exercise of Member States’ taxing powers; consideration of expenses related to economic activity and personal and family circumstances; and in-depth discussion of taxation of income derived from source versus residence Member State. Throughout the book, the author refers to the case law of the CJEU on both international juridical double taxation and taxpayers’ ability to pay, as well as the relevant academic literature, allowing the reader to understand the current state of EU law on these matters and their relation. The author’s remarkable venture into this challenging field, with a deeply informed construction of instrumental categories and critical review of their content, culminates with a viable reformulation of the serious and growing problem of international juridical double taxation. The book will be welcomed by taxation professionals in practice, policymakers, and academia.
Book Synopsis A Journey Through European and International Taxation by : Carla De Pietro
Download or read book A Journey Through European and International Taxation written by Carla De Pietro and published by Kluwer Law International B.V.. This book was released on 2024-03-06 with total page 625 pages. Available in PDF, EPUB and Kindle. Book excerpt: To some extent, because of his overlapping careers in academia and politics, the renowned tax scholar Peter Essers is known for his influential insight that ‘the effects of taxation on the political balance of power, and vice versa, are always interlinked with other phenomena, such as wars, crises, religious developments and inequalities in society’. In this widely ranging festschrift, thirty-six prominent tax scholars from all across Europe examine the legacy of Peter Essers’ research interests, from the larger philosophical, political, and social factors driving tax history to the reality of the taxing State as experienced by taxpayers and tax officials. The book’s outstanding overview of the most relevant technical and policy aspects of European and international taxation includes deeply thoughtful chapters on such topics and issues as the following: developing sustainable corporate tax governance; tax whistleblowing; transfer pricing; balancing qualitative and quantitative approaches to tax research; necessity to reach something close to ‘equal treatment’ between the upper and lower social classes; consent and democracy; tax rebellions; tax evasion and tax avoidance; taxation of cross-border remote workers and their employers; mitigation of double taxation of income earned by entertainers and sportspersons; and the international tax treaty network. More than a homage to this scholar’s far-reaching contributions, this book is remarkable for the variety and academic rigour of the chapters. The understanding its authors provide of both the broad contours and the intricacies of European and international taxation will be of inestimable value to tax practitioners, policymakers, tax consultants, and academics, as well as interested researchers in economics, political science, and sociology.
Book Synopsis Formulary Apportionment for the Internal Market by : Stefan Mayer
Download or read book Formulary Apportionment for the Internal Market written by Stefan Mayer and published by IBFD. This book was released on 2009 with total page 355 pages. Available in PDF, EPUB and Kindle. Book excerpt: Since its Company Tax Communication of 2001, the European Commission has been promoting a comprehensive harmonization of corporation taxes within the Internal Market on the basis of consolidation and formulary apportionment of the profits of cross-border enterprises, both in the form of a Home State Taxation (HST) and of the Common Consolidated Corporate Tax Base. This study assesses whether this approach represents a viable alternative to the arm's length standard currently applied in international tax law. The study comprises four parts. First, a theoretical concept of formulary apportionment is presented, followed by an evaluation of the practical experiences of four jurisdictions (United States, Canada, Switzerland and Germany) with formulary apportionment at the subnational level. Next, a proposal for harmonization on the basis of consolidation and apportionment is developed, and the book concludes with an overall analysis of the merits and drawbacks of the proposed model for harmonization.
Book Synopsis Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax by : Mr. Shafik Hebous
Download or read book Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax written by Mr. Shafik Hebous and published by International Monetary Fund. This book was released on 2024-03-15 with total page 41 pages. Available in PDF, EPUB and Kindle. Book excerpt: The international agreement on a corporate minimum tax is a milestone in global corporate tax arrangements. The minimum tax disturbs the equivalence between otherwise equivalent forms of efficient economic rent taxation: cash-flow tax and allowance for corporate equity. The marginal effective tax rate initially declines as the statutory tax rate rises, reaching zero where the minimum tax is inapplicable, and increases thereafter. This kink occurs at a lower statutory rate under cash-flow taxation. We relax the assumption of full loss offset; provide a routine for computing effective rates under different designs; and discuss policy implications of the minimum tax.
Download or read book Tax Notes International written by and published by . This book was released on 2004 with total page 1218 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Bulletin for International Fiscal Documentation by :
Download or read book Bulletin for International Fiscal Documentation written by and published by . This book was released on 2001 with total page 718 pages. Available in PDF, EPUB and Kindle. Book excerpt:
