The Role Of Allocation In A Globalized Corporate Income Tax
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The Role of Allocation in a Globalized Corporate Income Tax by Mr.Jack M. Mintz Pdf
The internationalization of business activity has created significant pressures on national corporate tax systems. Rather than abandon the corporate tax field, this paper predicts that governments will develop arrangements to further globalize the corporate income tax. The paper assesses the merits and limitations of allocation methods for attributing income to different jurisdictions according to formulas measuring business activity. Such methods are being used as part of transfer pricing regimes and are likely to be enhanced over time. Whatever international arrangements develop in the future, there is a role for new institutions to improve cooperative discussions among governments.
The Role of Allocation in a Globalized Corporate Income Tax by Jack Mintz Pdf
The internationalization of business activity has created significant pressures on national corporate tax systems. Rather than abandon the corporate tax field, this paper predicts that governments will develop arrangements to further globalize the corporate income tax. The paper assesses the merits and limitations of allocation methods for attributing income to different jurisdictions according to formulas measuring business activity. Such methods are being used as part of transfer pricing regimes and are likely to be enhanced over time. Whatever international arrangements develop in the future, there is a role for new institutions to improve cooperative discussions among governments.
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option by Richard Krever Pdf
The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246
Taxes and the Global Allocation of Capital by David Backus,Espen Henriksen,Kjetil Storesletten Pdf
Despite enormous growth in international capital flows, capital-output ratios continue to exhibit substantial heterogeneity across countries. We explore the possibility that taxes, particularly corporate taxes, are a significant source of this heterogeneity. The evidence is mixed. Tax rates computed from tax revenue are inversely correlated with capital-output ratios, as we might expect. However, effective tax rates constructed from official tax rates show little relation to capital -- or to revenue-based tax measures. The stark difference between these two tax measures remains an open issue.
Taxation in the Global Economy by Assaf Razin,Joel Slemrod Pdf
The increasing globalization of economic activity is bringing an awareness of the international consequences of tax policy. The move toward the common European market in 1992 raises the important question of how inefficiencies in the various tax systems—such as self-defeating tax competition among member nations—will be addressed. As barriers to trade and investment tumble, cross-national differences in tax structures may loom larger and create incentives for relocations of capital and labor; and efficient and equitable income tax systems are becoming more difficult to administer and enforce, particularly because of the growing importance of multinational enterprises. What will be the role of tax policy in this more integrated world economy? Assaf Razin and Joel Slemrod gathered experts from two traditionally distinct specialties, taxation and international economics, to lay the groundwork for understanding these issues, which will require the attention of scholars and policymakers for years to come. Contributors describe the basic provisions of the U.S. tax code with respect to international transactions, highlighting the changes contained in the U.S. Tax Reform Act of 1986; explore the ways that tax systems influence the decisions of multinationals; examine the effect of taxation on trade patterns and capital flows; and discuss the implications of the opening world economy for the design of optimal international tax policy. The papers will prove valuable not only to scholars and students, but to government economists and international tax lawyers as well.
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.
This work is a comprehensive collection of cutting-edge scholarship on the economic, international business, political, legal, and environmental ramifications of globalization—one of the hottest topics of the day. International trade is as old as nations. During the last five decades, however, advances in technology and transportation have changed the scope and method of international trade. Disputes rage about the effects of these changes; advocates for different positions offer argument, but little factual or theoretical analysis. Globalization offers all the information readers need to sort out the arguments. Written with the highest degree of scholarship, intended for college students or working professionals, the encyclopedia provides both introductory material to broad economic, legal, political, and environmental theory, and in-depth analysis of how theory interacts with practice in the framework of global trade. A trader in New York can, in a matter of seconds, execute a billion-dollar currency transaction in Hong Kong. What does this transaction mean to New Yorkers, to residents of Hong Kong, and to the rest of the world? This book gives readers the tools to answer those questions.
Tax Sovereignty and the Law in the Digital and Global Economy by Francesco Farri Pdf
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.
Consequences of the Economic and Monetary Union for the Coordination of Tax Systems in the European Union by Mr.Vito Tanzi,Mr.Howell H. Zee Pdf
With the advent of the economic and monetary union in the European Union (EU), the economic landscape of the EU will bear a striking resemblance to that of the United States in terms of fundamental attributes such as the freedom of internal movements of individuals, capital, and goods within the union, as well as the adoption of a common currency. This paper examines developments in the tax systems of the states in the United States and draws lessons for the need of coordination of EU tax systems.
An Open Economy Macroeconomics Reader by Mehmet Ugur Pdf
This book draws together the seminal contributions to the literature on the nature of macroeconomics in open economies and illuminates the material. This is an essential guide to the subject for students.
Taxation in a Global Economy by Andreas Haufler Pdf
The increasing international mobility of capital, firms and consumers has begun to constrain tax policies in most OECD countries, playing a major role in reforming national tax systems. Haufler uses the theory of international taxation to consider the fundamental forces underlying this process, covering both factor and commodity taxes, as well as their interaction. Topics include a variety of different international tax avoidance strategies - capital flight, profit shifting in multinational firms, and cross-border shopping by consumers. Situations in which tax competition creates conflicting interests between countries are given particular consideration. Haufler addresses the complex issue of coordination in different areas of tax policy, with special emphasis on regional tax harmonization in the European Union. Also included is a detailed introduction to recent theoretical literature.
Author : Michael S. Greve Publisher : American Enterprise Institute Page : 64 pages File Size : 49,8 Mb Release : 2003 Category : Business & Economics ISBN : 0844771708
Company Tax Reform in the European Union by Joann Martens-Weiner Pdf
Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.
IMF Staff papers, Volume 45 No. 4 by International Monetary Fund. Research Dept. Pdf
This paper describes the issue of corruption around the world. The paper surveys and discusses issues related to the causes, consequences, and scope of corruption, and possible corrective actions. It emphasizes the costs of corruption in terms of economic growth. It also emphasizes that the fight against corruption may not be cheap and cannot be independent from the reform of the state. If certain reforms are not made, corruption is likely to continue to be a problem regardless of actions directly aimed at curtailing it.
