Exploring Residual Profit Allocation

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Exploring Residual Profit Allocation

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

Author : Sebastian Beer,Ruud A. de Mooij,Shafik Hebous,Mr.Michael Keen,Ms.Li Liu
Publisher : International Monetary Fund
Page : 51 pages
File Size : 48,8 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.

Tax by Design for the Netherlands

Sijbren Cnossen,Bas Jacobs
Tax by Design for the Netherlands Book PDF

Author : Sijbren Cnossen,Bas Jacobs
Publisher : Oxford University Press
Page : 450 pages
File Size : 48,7 Mb
Release : 2021-12-16
Category : Business & Economics
ISBN : 9780192667489

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

The Dutch tax system distorts economic decisions, treats equal economic positions unequally for tax purposes, and is extraordinarily complex. Following in the footsteps of the Mirrlees Review, prominent economists from academia and the policy arena, at home and abroad, provide independent, evidence-based analyses of the system's shortcomings, as well as detailed proposals for reform. Tax by Design for the Netherlands spans the whole spectrum of taxes on labor and capital income, profits, consumption, wealth, inheritance, and charges to correct for market and individual failure, including the environment.

The Oxford Handbook of International Tax Law

Florian Haase,Georg Kofler
The Oxford Handbook of International Tax Law Book PDF

Author : Florian Haase,Georg Kofler
Publisher : Oxford University Press
Page : 1185 pages
File Size : 44,6 Mb
Release : 2023-09-22
Category : Law
ISBN : 9780192652348

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The Oxford Handbook of International Tax Law by Florian Haase,Georg Kofler Pdf

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.

Corporate Income Taxes under Pressure

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

Author : Ruud A. de Mooij,Mr.Alexander D Klemm,Ms.Victoria J Perry
Publisher : International Monetary Fund
Page : 388 pages
File Size : 46,9 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.

Taxing Profit in a Global Economy

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

Author : Michael P. Devereux,Alan J. Auerbach,Michael Keen,Paul Oosterhuis,John Vella,Wolfgang Schön
Publisher : Oxford University Press
Page : 401 pages
File Size : 49,8 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.

Taxing Multinationals in Europe

Ernesto Crivelli,Ruud A. de Mooij,J. E. J. De Vrijer,Mr. Shafik Hebous,Mr. Alexander D Klemm
Taxing Multinationals in Europe Book PDF

Author : Ernesto Crivelli,Ruud A. de Mooij,J. E. J. De Vrijer,Mr. Shafik Hebous,Mr. Alexander D Klemm
Publisher : International Monetary Fund
Page : 61 pages
File Size : 41,9 Mb
Release : 2021-05-25
Category : Business & Economics
ISBN : 9781513570761

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Taxing Multinationals in Europe by Ernesto Crivelli,Ruud A. de Mooij,J. E. J. De Vrijer,Mr. Shafik Hebous,Mr. Alexander D Klemm Pdf

This paper aims to contribute to the European policy debate on corporate income tax reform in three ways. First, it takes a step back to review the performance of the CIT in Europe over the past several decades and the important role played by MNEs in European economies. Second, it analyses corporate tax spillovers in Europe with a focus on the channels and magnitudes of both profit shifting and CIT competition. Third, the paper examines the progress made in European CIT coordination and discusses reforms to strengthen the harmonization of corporate tax policies, in order to effectively reduce both tax competition and profit shifting.

Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax

Mr. Shafik Hebous,Andualem Mengistu
Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax Book PDF

Author : Mr. Shafik Hebous,Andualem Mengistu
Publisher : International Monetary Fund
Page : 41 pages
File Size : 53,5 Mb
Release : 2024-03-15
Category : Business & Economics
ISBN : 9798400271014

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Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax by Mr. Shafik Hebous,Andualem Mengistu Pdf

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.

Fiscal Monitor, April 2022

International Monetary Fund
Fiscal Monitor April 2022 Book PDF

Author : International Monetary Fund
Publisher : International Monetary Fund
Page : 124 pages
File Size : 43,8 Mb
Release : 2022-04-20
Category : Business & Economics
ISBN : 9781513598789

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Fiscal Monitor, April 2022 by International Monetary Fund Pdf

Chapter 1 discusses how fiscal policy operates amid a sharp rise in uncertainty caused by the war in Ukraine. Chapter 2 discusses how international coordination on tax matters can support revenue, inclusion, tax transparency, and greener economies.

Digitalization and Taxation in Asia

Ms. Era Dabla-Norris,Ruud de Mooij,Andrew Hodge,Jan Loeprick,Dinar Prihardini,Ms. Alpa Shah,Sebastian Beer,Sonja Davidovic,Arbind M Modi,Fan Qi
Digitalization and Taxation in Asia Book PDF

Author : Ms. Era Dabla-Norris,Ruud de Mooij,Andrew Hodge,Jan Loeprick,Dinar Prihardini,Ms. Alpa Shah,Sebastian Beer,Sonja Davidovic,Arbind M Modi,Fan Qi
Publisher : International Monetary Fund
Page : 75 pages
File Size : 54,9 Mb
Release : 2021-09-14
Category : Business & Economics
ISBN : 9781513577425

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Digitalization and Taxation in Asia by Ms. Era Dabla-Norris,Ruud de Mooij,Andrew Hodge,Jan Loeprick,Dinar Prihardini,Ms. Alpa Shah,Sebastian Beer,Sonja Davidovic,Arbind M Modi,Fan Qi Pdf

Digitalization in Asia is pervasive, unique, and growing. It stands out by its sheer scale, with internet users far exceeding numbers in other regions. This facilitates e-commerce in markets that are large by international standards, supported by innovative payment systems and featuring major corporate players, including a number of large, home-grown, highly digitalized businesses (tech giants) that rival US multinational enterprises (MNEs) in size. Opportunity for future growth exists, as a significant population share remains unconnected.

Keeping it Simple–Efficiency Costs of Fixed Margin Regimes in Transfer Pricing

Sebastian Beer,Sebastien Leduc,Jan Loeprick
Keeping it Simple Efficiency Costs of Fixed Margin Regimes in Transfer Pricing Book PDF

Author : Sebastian Beer,Sebastien Leduc,Jan Loeprick
Publisher : International Monetary Fund
Page : 27 pages
File Size : 54,5 Mb
Release : 2022-09-23
Category : Business & Economics
ISBN : 9798400219221

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Keeping it Simple–Efficiency Costs of Fixed Margin Regimes in Transfer Pricing by Sebastian Beer,Sebastien Leduc,Jan Loeprick Pdf

Simplifying tax policy comes with costs and benefits. This paper explores simplification options for the taxation of MNEs, an area where administrative and compliance costs of the current rules are large. Simplified approaches seek to reduce these costs by relying on an approximation of the true tax base, potentially distorting resource allocation. We examine the efficiency cost of transfer pricing simplification theoretically and empirically. Using a sample of 300,000 firms located in 22 countries, we estimate that common transfer pricing practices reduce efficiency between 0.25 and 2.2 percent of total factor productivity across sectors. Focusing on the manufacturing sector, we then observe that simplification more than doubles sectoral inefficiency on average. However, large differences exist, with moderate efficiency costs in several sectors.

International Corporate Tax Reform

International Monetary,International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept.
International Corporate Tax Reform Book PDF

Author : International Monetary,International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept.
Publisher : International Monetary Fund
Page : 59 pages
File Size : 49,5 Mb
Release : 2023-02-06
Category : Business & Economics
ISBN : 9798400232558

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International Corporate Tax Reform by International Monetary,International Monetary Fund. Fiscal Affairs Dept.,International Monetary Fund. Legal Dept. Pdf

To relieve the pressure on the outdated international corporate tax system, an ambitious reform was agreed at the Inclusive Framework (IF) on Base Erosion and Profit Shifting in 2021, with now 138 jurisdictions joining. It complements previous efforts to mitigate profit shifting by addressing the challenges of the digitalization of the economy through a new allocation of taxing rights to market economies (Pillar 1) and tax competition through a global minimum corporate tax (Pillar 2). This paper concludes that the agreement makes the international tax system more robust to tax spillovers, better equipped to address digitalization, and modestly raises global tax revenues.

Action Plan on Base Erosion and Profit Shifting

OECD
Action Plan on Base Erosion and Profit Shifting Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 44 pages
File Size : 44,7 Mb
Release : 2013-07-19
Category : Electronic
ISBN : 9789264202719

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Action Plan on Base Erosion and Profit Shifting by OECD Pdf

This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.

OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Report on Pillar One Blueprint Inclusive Framework on BEPS

OECD
OECD G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation Report on Pillar One Blueprint Inclusive Framework on BEPS Book PDF

Author : OECD
Publisher : OECD Publishing
Page : 230 pages
File Size : 48,6 Mb
Release : 2020-10-14
Category : Electronic
ISBN : 9789264289321

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OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from Digitalisation – Report on Pillar One Blueprint Inclusive Framework on BEPS by OECD Pdf

The OECD/G20 Base Erosion and Profit Shifting (BEPS) Project aims to create a single set of consensus-based international tax rules to address BEPS, and hence to protect tax bases while offering increased certainty and predictability to taxpayers. This report focuses on new nexus and profit allocation rules to ensure that, in an increasingly digital age, the allocation of taxing rights with respect to business profits is no longer exclusively circumscribed by reference to physical presence.

The Future of the Profit Split Method

Gabriella Cappelleri,Robert Danon,Vikram Chand
The Future of the Profit Split Method Book PDF

Author : Gabriella Cappelleri,Robert Danon,Vikram Chand
Publisher : Kluwer Law International B.V.
Page : 341 pages
File Size : 55,9 Mb
Release : 2020-11-23
Category : Law
ISBN : 9789403524313

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The Future of the Profit Split Method by Gabriella Cappelleri,Robert Danon,Vikram Chand Pdf

The Future of the Profit Split Method Edited by Robert Danon, Guglielmo Maisto, Vikram Chand & Gabriella Cappelleri Among the various transfer pricing methods, the profit split method (PSM) is under the spotlight after the OECD’s Base Erosion and Profit Shifting (BEPS) project. However, both expert analysis and experience indicate that this method is not straightforward either for taxpayers to apply or for tax administrations to evaluate. In this thorough and detailed commentary – the first book to analyse this increasingly adopted transfer pricing method – notable scholars and practitioners working in the international tax community express their views on the method, answering some unresolved questions and highlighting issues that are still open and pending, especially in light of the digitalization of the economy. Crucial issues covered by the contributors include the following: choice of the appropriate splitting factors, their relative weights, and valuation of the contributions; uncertainties and outcomes potentially not aligned with the arm’s-length standard; possible role of assessments made by the European Commission on State aid; nexus with the work done by the EU Joint Transfer Pricing Forum; impact of profit split on indirect taxes (VAT/customs tax/excise tax); and application to digital business models and, in general, to the digitalized economy. Moreover, relevant experience of applying this method in France, Germany, Italy, Spain, Switzerland, the United Kingdom, and the United States is provided. A concluding chapter also deals with selected industry experiences. Due to a high level of uncertainty in alignment with international guidance in the application of the PSM – and to the underdeveloped nature of current literature on the subject – there is a need for this book because both tax administrations and taxpayers, going forward, will apply the PSM extensively. The book is highly relevant for policymakers, tax administrations, practitioners and academics engaged in the areas of international taxation, transfer pricing and tax policy.

Exploring the Trust and Innovation Mechanisms in M&A of China’s State Owned Enterprises with Mixed Ownership

Yan Wang
Exploring the Trust and Innovation Mechanisms in M A of China s State Owned Enterprises with Mixed Ownership Book PDF

Author : Yan Wang
Publisher : Springer Nature
Page : 353 pages
File Size : 52,6 Mb
Release : 2021-09-20
Category : Business & Economics
ISBN : 9789811644047

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Exploring the Trust and Innovation Mechanisms in M&A of China’s State Owned Enterprises with Mixed Ownership by Yan Wang Pdf

This book is dedicated to strategic management research relating to China’s SOE. As China’s economic system of the day is featured by mixed ownership, state-owned enterprises (SOEs), under the New Normal of economic backdrop, are devoted to exploring the reform of stock resources reorganization, one of which is through mergers and acquisitions (M&A). This book explores the key points and difficulties in the successful reform of Chinese enterprises with mixed ownership by focusing on trust and innovation and by widely covering normative research, index evaluation system, game theory and empirical research with case study. It is significant for evaluating the reform of SOE in China by integrating the informal institutional aspects into the formal one and understanding the leading role of SOE in China’s economic development.