A Destination Based Allowance For Corporate Equity

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A Destination-Based Allowance for Corporate Equity

Author : Shafik Hebous,Mr.Alexander D Klemm
Publisher : International Monetary Fund
Page : 26 pages
File Size : 40,7 Mb
Release : 2018-11-08
Category : Business & Economics
ISBN : 9781484381908

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A Destination-Based Allowance for Corporate Equity by Shafik Hebous,Mr.Alexander D Klemm Pdf

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.

Allowances for Corporate Equity in Practice

Author : Alexander Klemm
Publisher : Unknown
Page : 40 pages
File Size : 50,7 Mb
Release : 2006
Category : Corporations
ISBN : UCSD:31822034343483

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Allowances for Corporate Equity in Practice by Alexander Klemm Pdf

This paper provides an overview of full and partial allowance for corporate equity (ACE) tax systems in practice. In the recent past, ACE systems have been used in Austria, Croatia, and Italy. Brazil still applies a variant of such a system and Belgium introduced one this year. This paper summarizes the empirical literature on past ACE systems, and provides a theoretical and empirical assessment of the Brazilian ACE variant. The main finding is that the Brazilian reform introduced an ACE system for a minority of firms only, with the majority instead having a system of dividend deductibility. Despite the reduction in the tax preference for debt finance, capital structures have not changed much, but dividends have increased. Investment appears to have benefited from the reform, although the extent to which this was due to the new structure rather than the tax cut is unclear

OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax

Author : OECD
Publisher : OECD Publishing
Page : 174 pages
File Size : 50,5 Mb
Release : 2007-11-13
Category : Electronic
ISBN : 9789264038127

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OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax by OECD Pdf

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.

Corporate Taxation in the Global Economy

Author : International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept.
Publisher : International Monetary Fund
Page : 91 pages
File Size : 41,5 Mb
Release : 2019-03-10
Category : Business & Economics
ISBN : 9781498302197

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Corporate Taxation in the Global Economy by International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept. Pdf

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.

Tax Policy, Leverage and Macroeconomic Stability

Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
Page : 78 pages
File Size : 55,6 Mb
Release : 2016-12-10
Category : Business & Economics
ISBN : 9781498345200

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Tax Policy, Leverage and Macroeconomic Stability by International Monetary Fund. Fiscal Affairs Dept. Pdf

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.

Corporate Income Taxes under Pressure

Author : Ruud A. de Mooij,Mr.Alexander D Klemm,Ms.Victoria J Perry
Publisher : International Monetary Fund
Page : 388 pages
File Size : 55,7 Mb
Release : 2021-02-26
Category : Business & Economics
ISBN : 9781513511771

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Corporate Income Taxes under Pressure by Ruud A. de Mooij,Mr.Alexander D Klemm,Ms.Victoria J Perry Pdf

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.

Exploring Residual Profit Allocation

Author : Sebastian Beer,Ruud A. de Mooij,Shafik Hebous,Mr.Michael Keen,Ms.Li Liu
Publisher : International Monetary Fund
Page : 51 pages
File Size : 42,9 Mb
Release : 2020-02-28
Category : Business & Economics
ISBN : 9781513528328

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Exploring Residual Profit Allocation by Sebastian Beer,Ruud A. de Mooij,Shafik Hebous,Mr.Michael Keen,Ms.Li Liu Pdf

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.

Taxing Profit in a Global Economy

Author : Michael P. Devereux,Alan J. Auerbach,Michael Keen,Paul Oosterhuis,John Vella,Wolfgang Schön
Publisher : Oxford University Press
Page : 401 pages
File Size : 45,6 Mb
Release : 2020-09-29
Category : Business & Economics
ISBN : 9780198808060

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Taxing Profit in a Global Economy by Michael P. Devereux,Alan J. Auerbach,Michael Keen,Paul Oosterhuis,John Vella,Wolfgang Schön Pdf

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.

The Great Demographic Reversal

Author : Charles Goodhart,Manoj Pradhan
Publisher : Springer Nature
Page : 260 pages
File Size : 46,6 Mb
Release : 2020-08-08
Category : Business & Economics
ISBN : 9783030426576

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The Great Demographic Reversal by Charles Goodhart,Manoj Pradhan Pdf

This original and panoramic book proposes that the underlying forces of demography and globalisation will shortly reverse three multi-decade global trends – it will raise inflation and interest rates, but lead to a pullback in inequality. “Whatever the future holds”, the authors argue, “it will be nothing like the past”. Deflationary headwinds over the last three decades have been primarily due to an enormous surge in the world’s available labour supply, owing to very favourable demographic trends and the entry of China and Eastern Europe into the world’s trading system. This book demonstrates how these demographic trends are on the point of reversing sharply, coinciding with a retreat from globalisation. The result? Ageing can be expected to raise inflation and interest rates, bringing a slew of problems for an over-indebted world economy, but is also anticipated to increase the share of labour, so that inequality falls. Covering many social and political factors, as well as those that are more purely macroeconomic, the authors address topics including ageing, dementia, inequality, populism, retirement and debt finance, among others. This book will be of interest and understandable to anyone with an interest on where the world’s economy may be going.

Studies in the History of Tax Law, Volume 11

Author : Peter Harris,Dominic de Cogan
Publisher : Bloomsbury Publishing
Page : 529 pages
File Size : 54,8 Mb
Release : 2023-09-21
Category : Law
ISBN : 9781509963287

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Studies in the History of Tax Law, Volume 11 by Peter Harris,Dominic de Cogan Pdf

This book is a continuation of the prestigious series which is drawn from the papers of the biennial Cambridge Tax Law History Conference. The authors are a mix of academics and senior tax professionals from the judiciary and practice with representatives from 9 countries. The series continues to investigate current tax policy debates in an historical context. The papers fall within 3 basic categories: 1. UK and Irish tax, looking at a variety of topics such as tax administration, cases and judges (Whitney, Singer, Viscount Radcliffe), the taxation of royal forests, the taxation of spirits, and income tax transition in the Irish Free State; 2. International taxation, with chapters on the role of international organisations (OECD, League of Nations) and on South Africa's early attempts to address double taxation (tax treaties); and 3. Non-UK tax systems, including chapters on the legacy of colonial influence (Dutch East Indies), early developments in China, New Zealand, and the USA, an influential Canadian report (Carter Commission), development of the GAAR in Scandanavia, and the receipt of Roman tax law in Europe.

Brazil: Tax Expenditure Rationalization Within Broader Tax Reform

Author : Maria Delgado Coelho
Publisher : International Monetary Fund
Page : 46 pages
File Size : 52,5 Mb
Release : 2021-09-24
Category : Business & Economics
ISBN : 9781513596624

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Brazil: Tax Expenditure Rationalization Within Broader Tax Reform by Maria Delgado Coelho Pdf

The excessive complexity and burden of the Brazilian tax system, riddled by cumulative indirect taxes and heavy payroll contributions, have led to an accumulation of fiscal incentives aimed at reducing its burden on taxpayers and productive activities. Federal and subnational tax expenditures currently stand at over 5 percent of GDP. Rationalizing them can only be comprehensively feasible in the context of a broader sequenced tax reform, and could reduce resource misallocation and income inequality, as well as provide new revenues.

Revenue Implications of Destination-Based Cash-Flow Taxation

Author : Shafik Hebous,Mr.Alexander D Klemm,Saila Stausholm
Publisher : International Monetary Fund
Page : 35 pages
File Size : 41,9 Mb
Release : 2019-01-15
Category : Business & Economics
ISBN : 9781484392935

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Revenue Implications of Destination-Based Cash-Flow Taxation by Shafik Hebous,Mr.Alexander D Klemm,Saila Stausholm Pdf

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.

Tax by Design for the Netherlands

Author : Sijbren Cnossen,Bas Jacobs
Publisher : Oxford University Press
Page : 450 pages
File Size : 41,7 Mb
Release : 2022
Category : Business & Economics
ISBN : 9780192855244

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Tax by Design for the Netherlands by Sijbren Cnossen,Bas Jacobs Pdf

"This book is the product of the first Cnossen Forum-Tax by design for the Netherlands that was held on 23-24 May 2019."--Page v.

The Dynamics of Taxation

Author : Glen Loutzenhiser,Rita de la Feria
Publisher : Bloomsbury Publishing
Page : 384 pages
File Size : 48,5 Mb
Release : 2020-10-15
Category : Law
ISBN : 9781509929108

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The Dynamics of Taxation by Glen Loutzenhiser,Rita de la Feria Pdf

This book brings together a landmark collection of essays on tax law and policy to celebrate the legacy of Professor Judith Freedman. It focuses on the four areas of taxation scholarship to which she made her most notable contributions: taxation of SMEs and individuals, tax avoidance, tax administration, and taxpayers' rights and procedures. Professor Freedman has been a major driving force behind the development of tax law and policy scholarship, not only in the UK, but worldwide. The strength and diversity of the contributors to this book highlight the breadth of Professor Freedman's impact within tax scholarship. The list encompasses some of the most renowned taxation experts worldwide; they include lawyers, economists, academics and practitioners, from Britain, Canada, Portugal, Australia, Germany, Italy, Malta, Ireland, and Ukraine.

The Handbook of Global Shadow Banking, Volume I

Author : Luc Nijs
Publisher : Springer Nature
Page : 822 pages
File Size : 52,8 Mb
Release : 2020-06-30
Category : Business & Economics
ISBN : 9783030347437

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The Handbook of Global Shadow Banking, Volume I by Luc Nijs Pdf

This global handbook provides an up-to-date and comprehensive overview of shadow banking, or market-based finance as it has been recently coined. Engaging in financial intermediary services outside of normal regulatory parameters, the shadow banking sector was arguably a critical factor in causing the 2007-2009 financial crisis. This volume focuses specifically on shadow banking activities, risk, policy and regulatory issues. It evaluates the nexus between policy design and regulatory output around the world, paying attention to the concept of risk in all its dimensions—the legal, financial, market, economic and monetary perspectives. Particular attention is given to spillover risk, contagion risk and systemic risk and their positioning and relevance in shadow banking activities. Newly introduced and incoming policies are evaluated in detail, as well as how risk is managed, observed and assessed, and how new regulation can potentially create new sources of risk. Volume I concludes with analysis of what will and still needs to happen in the event of another crisis. Proposing innovative suggestions for improvement, including a novel Pigovian tax to tame financial and systemic risks, this handbook is a must-read for professionals and policy-makers within the banking sector, as well as those researching economics and finance.