The Role Of Allocation In A Globalized Corporate Income Tax

Author : Mr.Jack M. Mintz
Publisher : International Monetary Fund
ISBN 13 : 1451855575
Total Pages : 40 pages
Book Rating : 4.79/5 ( download)

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Download or read book The Role of Allocation in a Globalized Corporate Income Tax written by Mr.Jack M. Mintz and published by International Monetary Fund. This book was released on 1998-09-01 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Author : Jack Mintz
Publisher :
ISBN 13 :
Total Pages : 39 pages
Book Rating : 4.53/5 ( download)

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Download or read book The Role of Allocation in a Globalized Corporate Income Tax written by Jack Mintz and published by . This book was released on 2006 with total page 39 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Author : Richard Krever
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403506156
Total Pages : 307 pages
Book Rating : 4.59/5 ( download)

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Download or read book The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option written by Richard Krever and published by Kluwer Law International B.V.. This book was released on 2020-02-20 with total page 307 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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

Author : Michael P. Devereux
Publisher : Oxford University Press
ISBN 13 : 0198808062
Total Pages : 401 pages
Book Rating : 4.60/5 ( download)

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Download or read book Taxing Profit in a Global Economy written by Michael P. Devereux and published by Oxford University Press. This book was released on 2020-09-29 with total page 401 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Author : Assaf Razin
Publisher : University of Chicago Press
ISBN 13 : 0226705889
Total Pages : 456 pages
Book Rating : 4.80/5 ( download)

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Download or read book Taxation in the Global Economy written by Assaf Razin and published by University of Chicago Press. This book was released on 2008-04-15 with total page 456 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Author : David Backus
Publisher :
ISBN 13 :
Total Pages : 44 pages
Book Rating : 4.79/5 ( download)

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Download or read book Taxes and the Global Allocation of Capital written by David Backus and published by . This book was released on 2007 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Author : Martin Feldstein
Publisher : University of Chicago Press
ISBN 13 : 0226241874
Total Pages : 338 pages
Book Rating : 4.76/5 ( download)

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Download or read book The Effects of Taxation on Multinational Corporations written by Martin Feldstein and published by University of Chicago Press. This book was released on 2007-12-01 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The tax rules of the United States and other countries have intended and unintended effects on the operations of multinational corporations, influencing everything from the formation and allocation of capital to competitive strategies. The growing importance of international business has led economists to reconsider whether current systems of taxing international income are viable in a world of significant capital market integration and global commercial competition. In an attempt to quantify the effect of tax policy on international investment choices, this volume presents in-depth analyses of the interaction of international tax rules and the investment decisions of multinational enterprises. Ten papers assess the role played by multinational firms and their investment in the U.S. economy and the design of international tax rules for multinational investment; analyze channels through which international tax rules affect the costs of international business activities; and examine ways in which international tax rules affect financing decisions of multinational firms. As a group, the papers demonstrate that international tax rules have significant effects on firms' investment and other financing decisions.

Author : Vito Tanzi
Publisher : International Monetary Fund
ISBN 13 :
Total Pages : 28 pages
Book Rating : 4.23/5 ( download)

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Download or read book Globalization, Tax Competition and the Future of Tax Systems written by Vito Tanzi and published by International Monetary Fund. This book was released on 1996-12 with total page 28 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper discusses the implications for tax systems of globalization of capital markets and of economies. It shows the extent to which particular taxes are affected by the globalization process. It speculates on future developments in this area and on tax competition.

Author : Thomas Pogge
Publisher : Oxford University Press
ISBN 13 : 019103861X
Total Pages : 383 pages
Book Rating : 4.17/5 ( download)

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Download or read book Global Tax Fairness written by Thomas Pogge and published by Oxford University Press. This book was released on 2016-02-04 with total page 383 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book addresses sixteen different reform proposals that are urgently needed to correct the fault lines in the international tax system as it exists today, and which deprive both developing and developed countries of critical tax resources. It offers clear and concrete ideas on how the reforms can be achieved and why they are important for a more just and equitable global system to prevail. The key to reducing the tax gap and consequent human rights deficit in poor countries is global financial transparency. Such transparency is essential to curbing illicit financial flows that drain less developed countries of capital and tax revenues, and are an impediment to sustainable development. A major break-through for financial transparency is now within reach. The policy reforms outlined in this book not only advance tax justice but also protect human rights by curtailing illegal activity and making available more resources for development. While the reforms are realistic they require both political and an informed and engaged civil society that can put pressure on governments and policy makers to act.

Author : Vito Tanzi
Publisher : Edward Elgar Publishing
ISBN 13 : 1788116879
Total Pages : 192 pages
Book Rating : 4.79/5 ( download)

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Download or read book The Ecology of Tax Systems written by Vito Tanzi and published by Edward Elgar Publishing. This book was released on 2018-03-30 with total page 192 pages. Available in PDF, EPUB and Kindle. Book excerpt: This groundbreaking book analyzes how the ecology of taxation is fundamental for the success or failure of tax systems. It specifically focuses on the role of the ecological environment on taxation; the factors that determine the ecology of taxation; and how the ecology of taxation has changed and may continue to evolve. The implicit, important conclusion is that there are no permanent or universal optimal tax theories: all theories are related to this ecology.