Deciphering The Globe In A Low Tax Jurisdiction

Author : Mr. Shafik Hebous
Publisher : International Monetary Fund
ISBN 13 :
Total Pages : 26 pages
Book Rating : 4.89/5 ( download)

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Download or read book Deciphering the GloBE in a Low-Tax Jurisdiction written by Mr. Shafik Hebous and published by International Monetary Fund. This book was released on 2024-03-22 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: Pillar Two rules of the Inclusive Framework agreement on a minimum corporate tax (known as ‘Global Anti-Base Erosion Rules’, for short GloBE) have important implications for the design of the corporate income tax. This chapter discusses these implications particularly from the perspective of low-tax jurisdictions. It argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. Importantly, if no profit tax already exists, countries need to consider whether to adopt one, and if yes, in what form. There is a case for introducing a general profit tax beyond the GloBE rules, together with a qualifying GloBE domestic minimum top-up tax as a backstop. The familiar alternatives of efficient economic rent tax designs, however, are no longer equivalent under the GloBE. In practice, given the specifics of the rules, an efficient rent tax on in-scope multinationals cannot be combined with a statutory tax rate below a certain cutoff, because the minimum tax becomes always binding. Under the GloBE, immediate expensing particularly maintains the time-value of fully deducting the cost of investment, without impacting the GloBE effective tax rate.

Author : Mr. Shafik Hebous
Publisher : International Monetary Fund
ISBN 13 :
Total Pages : 41 pages
Book Rating : 4.14/5 ( download)

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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.

Author : Kuldeep Sharma
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403511664
Total Pages : 340 pages
Book Rating : 4.65/5 ( download)

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Download or read book GloBE Rules Made Easy written by Kuldeep Sharma and published by Kluwer Law International B.V.. This book was released on 2022-12-09 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: Worldwide implementation of the OECD’s Global Anti-Base Erosion Rules (GloBE Rules), published in December 2021, promises to strike a powerful blow at the tax avoidance rampantly indulged in by many multinational corporations since global minimum tax rate of 15% in all countries is expected to curb shifting of profits from higher tax jurisdiction to lower tax jurisdiction or tax havens. As Inclusive Framework (IF) Member jurisdictions prepare to implement legislation, the tax law community worldwide can turn to this extraordinarily practical, self-contained book for a complete understanding of the background and attributes of the Rules. The book includes such features as the following: text of each of the Rules’ ten chapters (including all forty-nine articles) along with both summary and detailed description; explanations of the Commentary and Illustrative Examples released by the OECD in March 2022; numerous flowcharts, tables, boxes, illustrations, and figures; elaborate technical discussions amidst specific policy considerations; analysis of IF Member jurisdictions regarding key parameters with suitable recommendations; ‘GloBE Rules at a Glance’ checklist encapsulating the features and application of the Rules in the form of FAQs; and implementation processes under way in ten representative jurisdictions. The various publications and releases by the OECD up to 31 May 2022 are considered and duly explained. In the struggle to curb harmful tax competition and aggressive tax planning, it is possible that the GloBE Rules will at last succeed in creating a level playing field in the realm of taxation. And given that OECD guidance and tax expert analysis may not suffice to fully comprehend the complexity of the Rules, this book will prove of enormous value among a wide array of stakeholders, including taxation authorities, tax advisors and lawyers, and academics. Also, multinational enterprises will get enough information to derive maximum benefits in terms of their preparedness, readiness, and responses to implementation of the Rules.

Author : Jane Gravelle
Publisher :
ISBN 13 :
Total Pages : 0 pages
Book Rating : 4.17/5 ( download)

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Download or read book Tax Havens written by Jane Gravelle and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report discusses the State of the Union address, which is a communication between the President and Congress in which the chief executive reports on the current conditions of the United States and provides policy proposals for the upcoming legislative year.

Author : Lorraine Eden
Publisher : University of Toronto Press
ISBN 13 : 9780802007766
Total Pages : 788 pages
Book Rating : 4.67/5 ( download)

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Download or read book Taxing Multinationals written by Lorraine Eden and published by University of Toronto Press. This book was released on 1998-01-01 with total page 788 pages. Available in PDF, EPUB and Kindle. Book excerpt: Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.

Author : Werner Haslehner
Publisher : Edward Elgar Publishing
ISBN 13 : 1035308746
Total Pages : 353 pages
Book Rating : 4.43/5 ( download)

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Download or read book The 'Pillar Two' Global Minimum Tax written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2024-08-06 with total page 353 pages. Available in PDF, EPUB and Kindle. Book excerpt: Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.

Author : Valentin Bendlinger
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403532971
Total Pages : 449 pages
Book Rating : 4.74/5 ( download)

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Download or read book The OECD’s Global Minimum Tax and its Implementation in the EU – A Legal Analysis of Pillar Two in the Light of Tax Treaty and EU Law written by Valentin Bendlinger and published by Kluwer Law International B.V.. This book was released on 2023-10-17 with total page 449 pages. Available in PDF, EPUB and Kindle. Book excerpt: Rarely in the history of international tax law have there been so many evolutions in such a short space of time: In a dizzying array of reports, work programmes, consultations and announcements, the OECD, with the active support of the EU, has created a framework for a global minimum tax (Pillar Two or GloBE). In the meanwhile, jurisdictions are faced with the practical difficulties of incorporating an incredibly complex set of rules into their domestic legal systems. This book aims to shed light on the fundamental and technical issues surrounding the global minimum tax. It seeks to unravel the complex ramifications of GloBE’s technical framework and aims to explore the relationship between the OECD’s soft law materials, including the OECD’s GloBE Model Rules and the GloBE Commentary, tax treaties and the EU’s recently adopted GloBE-Directive. The author not only analyses Pillar Two from a technical and a policy perspective but also provides for a comprehensive examination of the compatibility of Pillar Two with tax treaties and EU law. To this end, the analysis also includes practical examples and illustrates solutions to numerous technical and policy issues of Pillar Two. Among the seminal matters covered are the following: History and Background of the global minimum tax discussion. Detailed technical considerations on the design of Pillar Two, including its scope, the determination of both the ‘GloBE Income’ as well as the ‘Adjusted Covered Taxes’ and the computation of the effective tax rate as well as the computation and collection of the final ‘Top-up Tax’ liability, including the application of the QDMTT, IIR, and UTPR. Tax policy implications and deficiencies of the final design of Pillar Two. The relation of Pillar Two to the current distribution of taxing rights under bilateral tax treaties. The analysis includes the compatibility of the QDMTT, IIR, and UTPR with existing tax treaties and the resolution of potential normative conflicts, both between tax treaties and domestic implementations of Pillar Two as well as between tax treaties concluded by EU Member States and the EU’s GloBE-Directive. The role of the GloBE-Directive within the EU’s legal order, including the issue of EU internal and external competence as well as the substantive compatibility of Pillar Two with primary law, such as the fundamental freedoms. Detailed comparisons between the OECD’s GloBE Model Rules and the EU’s GloBE-Directive elucidate common points and deviations. In addition to comprehensive technical considerations, the book also provides a comprehensive tax policy perspective on the global minimum tax. For its unparalleled clarification of the issues alone, this book will prove invaluable to practitioners, tax authorities, policymakers, and academics concerned with the implementation and application of Pillar Two. ‘Valentin Bendlinger’s book is an outstandingly remarkable work on a highly complex topic. The structure, clarity of thinking, and legal argumentation are excellent, and the legal and policy results throughout are profoundly argued. The book successfully ties together broad concepts of international and European (tax) law with highly complex and novel issues of the taxation of multinational enterprises. It should be highlighted that Valentin Bendlinger succeeded in leading the reader from the history and policy through a “jungle” of unprecedented rules to overarching fundamental issues of how the new taxation framework is to be placed in the international and European legal order.’ – Prof. DDr Georg Kofler, LLM (NYU), Vienna University of Economics and Business.

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264162941
Total Pages : 82 pages
Book Rating : 4.45/5 ( download)

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Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264814671
Total Pages : 334 pages
Book Rating : 4.77/5 ( download)

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Download or read book OECD/G20 Base Erosion and Profit Shifting Project Tax Challenges Arising from the Digitalisation of the Economy – Consolidated Commentary to the Global Anti-Base Erosion Model Rules (2023) Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2024-04-25 with total page 334 pages. Available in PDF, EPUB and Kindle. Book excerpt: A key part of the OECD/G20 BEPS Project is addressing the tax challenges arising from the digitalisation of the economy. In October 2021, over 135 jurisdictions joined a ground-breaking plan to update key elements of the international tax system which is no longer fit for purpose in a globalised and digitalised economy.

Author : Chris R. Edwards
Publisher : Cato Institute
ISBN 13 : 1933995181
Total Pages : 267 pages
Book Rating : 4.82/5 ( download)

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Download or read book Global Tax Revolution written by Chris R. Edwards and published by Cato Institute. This book was released on 2008 with total page 267 pages. Available in PDF, EPUB and Kindle. Book excerpt: Introduction -- Capital explosion -- Tax cut revolution -- Flat tax club -- Mobile brains and mobile wealth -- Taxing businesses in the global economy -- The economics of tax competition -- The battle for freedom and competition -- The moral case for tax competition -- Options for U.S. policy.