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Unilateral Introduction Of Destination Based Cash Flow Taxation
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Book Synopsis Unilateral Introduction of Destination Based Cash Flow Taxation by : Johannes Becker
Download or read book Unilateral Introduction of Destination Based Cash Flow Taxation written by Johannes Becker and published by . This book was released on 2018 with total page 17 pages. Available in PDF, EPUB and Kindle. Book excerpt: We analyze the unilateral introduction of a destination-based corporate cash-flow tax system (DBT), as recently proposed by Auerbach and Devereux (AEJ Policy 2018). We show that, first, the DBT rate is decision-neutral only if the source-tax country makes the DBT payments deductible from its tax base. Second, a unilateral DBT introduction is, in many aspects, equivalent to completely abolishing the corporate tax and, instead, taxing domestic investors based upon their worldwide profit income, net of foreign taxes and on accrual. In this sense, the DBT is actually a pure residence based tax. This implies that, from a foreign investor's perspective, the DBT country is like a zero-rate tax haven and has the same gravitational power on taxable (and shiftable) profits and economic activity. The location of profit and activity within its borders is, however, without any fiscal value for the DBT country. Third, the introduction of a DBT system reduces national income. Finally, the DBT country can only individually benefit from its new tax system if public goods provision is substantially increased.
Book Synopsis Unilateral Introduction of Destination-based Cash-flow Taxation by : Johannes Becker
Download or read book Unilateral Introduction of Destination-based Cash-flow Taxation written by Johannes Becker and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The article analyses the unilateral introduction of a destination-based corporate cash-flow tax system (DBT), as proposed by Auerbach and Devereux (AEJ Policy 2018). The authors show that, first, the DBT rate is decision-neutral only if the source tax country makes the DBT payments deductible from its taxbase. Second, a unilateral DBT introduction is, in many aspects, equivalent to completely abolishing the corporate tax and, instead, taxing domestic investors based upon their worldwide profit income, net of foreign taxes and on accrual. In this sense, the DBT is actually a pure residence-based tax. This implies that, from a foreign investor's perspective, the DBT country is like a zero rate tax haven and has the same gravitational power on taxable profits and economic activity. Third, the location of profit and activity within its borders is, however, without any fiscal value for the DBT country. Fourth, the introduction of a DBT system reduces national income. Fifth, the DBT country can only individually benefit from its new tax system if public goods provision is substantially increased. Finally, it is optimal to complement a unilateral DBT system with a source-based tax.
Book Synopsis Revenue Implications of Destination-Based Cash-Flow Taxation by : Shafik Hebous
Download or read book Revenue Implications of Destination-Based Cash-Flow Taxation written by Shafik Hebous and published by International Monetary Fund. This book was released on 2019-01-15 with total page 35 pages. Available in PDF, EPUB and Kindle. Book excerpt: We estimate the revenue implications of a Destination Based Cash Flow Tax (DBCFT) for 80 countries. On a global average, DBCFT revenues under unchanged tax rates would remain similar to the existing corporate income tax (CIT) revenue, but with sizable redistribution of revenue across countries. Countries are more likely to gain revenue if they have trade deficits, are not reliant on the resource sector, and/or—perhaps surprisingly—are developing economies. DBCFT revenues tend to be more volatile than CIT revenues. Moreover, we consider the revenue losses resulting from spillovers in case of unilateral implementation of a DBCFT. Results suggest that these spillover effects are sizeable if the adopting country is large and globally integrated. These spillovers generate strong revenue-based incentives for many—but not all—other countries to follow the DBCFT adoption.
Book Synopsis A European Perspective on the US Plans for a Destination Based Cash Flow Tax by : Johannes Becker
Download or read book A European Perspective on the US Plans for a Destination Based Cash Flow Tax written by Johannes Becker and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Unilateral Tax Reform by : Eric W. Bond
Download or read book Unilateral Tax Reform written by Eric W. Bond and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: We study the economic effects of unilateral adoption of corporate tax policies that include destination-based taxes and/or cash ow taxes in a heterogeneous agent model in which multinational firms can endogenously shift income between countries using transfer prices. Standard pass through arguments no longer apply because of the income shifting behavior of multinationals. Over or under- pass through will affect domestic consumer prices charged by multinational firms and will distort the decision of international businesses to outsource intermediate goods or to produce them in a foreign subsidiary. The welfare of the adopting country can decrease both with the adoption of destination-based taxes and the adoption of cash ow taxes. For a country with sufficiently large export markets that can optimally adjust its corporate tax rate on domestic earnings, unilaterally adopting cash ow taxation with full destination-based rate adjustments will reduce welfare.
Book Synopsis Destination-Based Cash-Flow Taxation by : Alan J. Auerbach
Download or read book Destination-Based Cash-Flow Taxation written by Alan J. Auerbach and published by . This book was released on 2016 with total page 33 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper presents, analyses, and further develops the idea of a destination-based cash-flow tax (DBCFT). Its purpose is expositional: to describe the DBCFT, how it might work, what its effects would be and some of the challenges that its implementation would face. The paper starts by introducing the basic mechanics of the DBCFT before evaluating it against five criteria: economic efficiency, robustness to avoidance and evasion, ease of administration, fairness and stability. It does so both for the case of universal adoption by all countries and the more plausible case of unilateral adoption. The paper then looks closely at the application of DBCFT treatment to the financial sector, which is a familiar problem under the VAT but has been little considered under the DBCFT. Finally, the paper sets out some core implementation issues, and how they might be addressed. It also compares the implementation of a DBCFT with the economically equivalent reform option that introduces a broad-based, uniform rate VAT (or achieves the same effect through an existing VAT), and reduces taxes on payroll by the same proportion.
Book Synopsis A Destination-Based Allowance for Corporate Equity by : Shafik Hebous
Download or read book A Destination-Based Allowance for Corporate Equity written by Shafik Hebous and published by International Monetary Fund. This book was released on 2018-11-08 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.
Book Synopsis Profit Shifting and Unilateral Adoption of Destination-Based Taxes by : Manon Francois
Download or read book Profit Shifting and Unilateral Adoption of Destination-Based Taxes written by Manon Francois and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper provides new insights into a key element of the global corporate tax reform agenda: the choice between a source-based and a destination-based corporate tax system. We study the government choice between source-based and destination-based taxes in a two-country model, allowing multinational firms to use transfer pricing to allocate profits across tax jurisdictions. Governments face a trade-off in choosing their tax system: under source-based taxation, high-tax countries suffer from profit shifting but can tax domestic and exporting firms, while under destination-based taxation, exports are untaxed, unlike imports and countries attract profits irrespective of their tax rate. Overall, we show that an exporting country would only unilaterally adopt a destination-based tax if it has a much higher tax rate than the source-based country. An importing country would only use a source-based tax when the exporting country also uses such a tax if both tax rates are close.
Book Synopsis United States Taxation of Foreign Investment Income by : Peggy B. Musgrave
Download or read book United States Taxation of Foreign Investment Income written by Peggy B. Musgrave and published by . This book was released on 1969 with total page 204 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 International Taxation of Trust Income by : Mark Brabazon
Download or read book International Taxation of Trust Income written by Mark Brabazon and published by Cambridge University Press. This book was released on 2019-05-02 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book identifies a set of principles and corresponding tax settings that countries may apply to cross-border income derived by, through, or from a trust and will appeal to international tax practitioners, administrators, policymakers, academics, and students.
Book Synopsis Cash-flow Tax by : Parthasarathi Shome
Download or read book Cash-flow Tax written by Parthasarathi Shome and published by . This book was released on 1993 with total page 36 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Dimensions of Tax Design by : James A. Mirrlees
Download or read book Dimensions of Tax Design written by James A. Mirrlees and published by Oxford University Press. This book was released on 2010-04-29 with total page 1360 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Review was chaired by Nobel Laureate Professor Sir James Mirrlees of the University of Cambridge and the Chinese University of Hong Kong. --
Book Synopsis North Country Will by : Durham Eng Surtees Society
Download or read book North Country Will written by Durham Eng Surtees Society and published by Legare Street Press. This book was released on 2023-07-18 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: North Country Will is a collection of ballads and songs from the north of England, edited by the Surtees Society of Durham. The book provides a fascinating insight into the culture and traditions of the region, and includes many songs that are still popular today. This work has been selected by scholars as being culturally important, and is part of the knowledge base of civilization as we know it. This work is in the "public domain in the United States of America, and possibly other nations. Within the United States, you may freely copy and distribute this work, as no entity (individual or corporate) has a copyright on the body of the work. Scholars believe, and we concur, that this work is important enough to be preserved, reproduced, and made generally available to the public. We appreciate your support of the preservation process, and thank you for being an important part of keeping this knowledge alive and relevant.
Book Synopsis Tax Policy, Leverage and Macroeconomic Stability by : International Monetary Fund. Fiscal Affairs Dept.
Download or read book Tax Policy, Leverage and Macroeconomic Stability written by International Monetary Fund. Fiscal Affairs Dept. and published by International Monetary Fund. This book was released on 2016-12-10 with total page 78 pages. Available in PDF, EPUB and Kindle. Book excerpt: Risks to macroeconomic stability posed by excessive private leverage are significantly amplified by tax distortions. ‘Debt bias’ (tax provisions favoring finance by debt rather than equity) has increased leverage in both the household and corporate sectors, and is now widely recognized as a significant macroeconomic concern. This paper presents new evidence of the extent of debt bias, including estimates for banks and non-bank financial institutions both before and after the global financial crisis. It presents policy options to alleviate debt bias, and assesses their effectiveness. The paper finds that thin capitalization rules restricting interest deductibility have only partially been able to address debt bias, but that an allowance for corporate equity has generally proved effective. The paper concludes that debt bias should feature prominently in countries’ tax reform plans in the coming years.
Book Synopsis The Oxford Handbook of International Tax Law by : Florian Haase
Download or read book The Oxford Handbook of International Tax Law written by Florian Haase and published by Oxford University Press. This book was released on 2023-09-22 with total page 1185 pages. Available in PDF, EPUB and Kindle. Book excerpt: International Tax Law is at a turning point. Increased tax transparency, the tackling of Base Erosion and Profit Shifting (BEPS), the reconstruction of the network of bilateral tax treaties, the renewed discussion about a fair and efficient allocation of taxing rights between States in a global, digitalized economy, and the bold push for minimum corporate taxation are some expressions of this shift. This new era also demonstrates the increased influence of international standard setters such as the OECD, the UN, and the EU. Each of these developments alone has the potential of being disruptive to the traditional world of international tax law, but together they have the potential to reshape the international tax system. The Oxford Handbook of International Tax Law provides a comprehensive exploration of these key issues which will shape the future of tax law. Divided into eight parts, this handbook traces the history of international tax law from its earliest days until the present, including reflections on the developments that have characterized the last one hundred years. The second section places tax law within the broader international context considering how it relates to public and private international law, as well as corporate, trade, and criminal law. Sections three and four consider key legal principles and issues such as regional tax treaty models, OECD dispute resolution, and transfer pricing versus formulary apportionment. Subsequent analysis places these issues within their European and cross-border contexts providing an assessment of the role of the ECJ, state aid, and cross-border VAT. Section seven broadens the scope of this analysis, asking how trends in recent major economies and regions have helped shape the current outlook. The final section considers emerging issues and the future of international tax law. With over sixty authors from 28 different countries, the Oxford Handbook of International Tax Law is an invaluable resource for scholars, academics, and practitioners alike.
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.
