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Tax Policy, Leverage and Macroeconomic Stability

Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
Page : 78 pages
File Size : 30,26 MB
Release : 2016-12-10
Category : Business & Economics
ISBN : 1498345204

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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.

International Taxation in an Era of Digital Disruption : Analyzing the Current Debate

Author : I. Grinberg
Publisher :
Page : pages
File Size : 45,31 MB
Release : 2019
Category :
ISBN :

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This paper sets out some considerations for U.S. international tax policymaking and international tax diplomacy in this uncertain environment. Part I briefly describes four disparate background considerations that should inform our thinking. Part IA describes the decline of the arm's-length standard, which underpinned our historic understandings about how to attribute profits as among entities within a multinational corporation (MNC). Part IB describes the relationship between the arm's-length standard, jurisdiction to tax, and the attribution of profits to permanent establishments (PE). It highlights that under OECD principles, attribution of profits to PEs is accomplished through application of the OECD's transfer pricing guidelines (TPG). Part IC recounts various acts of tax unilateralism abroad, often focused on the tech sector, and including the trend toward abandoning historic limits on jurisdiction to tax. Part ID describes the United States' 2017 tax reform in that global context, with a particular focus on the global intangible low-taxed income (GILTI) and the BEAT. Part II focuses on the European Commission and Her Majesty's Treasury (HMT) stated view that user participation should be acknowledged as a source of value creation in the digital economy and concludes that the user participation concept has application well beyond the so-called digital economy. Part III evaluates a version of the "marketing intangibles" idea and builds on the discussion about "where we go from here" in transfer pricing and concludes that splitting taxing rights over "excess" returns between the present transfer pricing system and a destination-based approached is complex. Part IV evaluates a version of a minimum tax system that combines inbound and outbound measures. Finally, the destination-based residual market profit allocation (DBRMPA) likely requires extensive tax harmonization and information exchange; more so than a minimum tax approach.

Fiscal Policies for Development and Climate Action

Author : Miria A. Pigato
Publisher : World Bank Publications
Page : 240 pages
File Size : 37,50 MB
Release : 2018-12-31
Category : Business & Economics
ISBN : 9781464813580

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This report provides actionable advice on how to design and implement fiscal policies for both development and climate action. Building on more than two decades of research in development and environmental economics, it argues that well-designed environmental tax reforms are especially valuable in developing countries, where they can reduce emissions, increase domestic revenues, and generate positive welfare effects such as cleaner water, safer roads, and improvements in human health. Moreover, these reforms need not harm competitiveness. New empirical evidence from Indonesia and Mexico suggests that under certain conditions, raising fuel prices can actually increase firm productivity. Finally, the report discusses the role of fiscal policy in strengthening resilience to climate change. It provides evidence that preventive public investments and measures to build fiscal buffers can help safeguard stability and growth in the face of rising climate risks. In this way, environmental tax reforms and climate risk-management strategies can lay the much-needed fiscal foundation for development and climate action.

Tax Sovereignty and the Law in the Digital and Global Economy

Author : Francesco Farri
Publisher : Routledge
Page : 249 pages
File Size : 45,57 MB
Release : 2020-09-27
Category : Business & Economics
ISBN : 1000217485

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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.

OECD Arbitration in Tax Treaty Law

Author : Alicja Majdanska
Publisher : Linde Verlag GmbH
Page : 740 pages
File Size : 40,24 MB
Release : 2018-09-14
Category : Law
ISBN : 3709409586

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Arbitration: the solution to tackle cross-border tax disputes From the increasing integration of the world economy and the lack of rules to govern the taxation of multinational enterprises to cross-border tax disputes: arbitration is one potential solution. Arbitration is not a new development in the international tax arena, but it has not yet been widely implemented in practice. In the last few years, the concept of arbitration in tax matters was revived, mainly following the OECD/G20 BEPS Project, as well as the EU Action Plan on Corporate Taxation. Now arbitration is expected to play a more significant role and enhance the existing framework of cross-border tax dispute resolution. „OECD Arbitration in Tax Treaty Law” constitutes a comprehensive compendium on international tax arbitration and provides in-depth analysis of all relevant aspects of the topic. The introductory chapters provide background information on tax arbitration and comparisons with other areas of law. The book also takes stock of the recent developments in this area within the OECD, the EU, the UN and the United States. It addresses the main concerns that have been raised with regard to arbitration, and compares and contrasts the design of various arbitration clauses. It also considers potential future developments. This compendium on international tax arbitration shows one way how to tackle the rising tide of cross-border tax disputes.

A Multilateral Convention for Tax

Author : Sergio André Rocha
Publisher : Kluwer Law International B.V.
Page : 401 pages
File Size : 29,68 MB
Release : 2021-11-29
Category : Law
ISBN : 9041194290

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The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) is the most forceful multilateral initiative to coordinate tax regimes on a worldwide basis since the dawn of modern income taxation over a century ago. This book evaluates two radically opposed viewpoints on the convention—a momentous and revolutionary paradigm shift versus a mechanism that merely continues an ongoing flow of limited policy coordination—with detailed investigations that bring to life the hopes and the realities of the current era of multilateral tax cooperation. Bringing together authors from national jurisdictions across the globe to scrutinize the MLI and its likely future ramifications, the book provides in-depth commentary and analysis in the following sequence: first, a comprehensive discussion of the design and goals of the MLI as a treaty and an institutional framework; second, an overview of the structure of the convention and its take-up across the globe to date; and third, the substantive implementation of the MLI with a wide range of country reports. Practice areas covered include tax law, international law, and international relations. The legal workings and implications of the MLI might still seem mysterious to those whose daily work is impacted by it, and there is as yet little jurisprudence regarding its legal nature or ultimate effect on the bilateral treaties coming within its scope. For these reasons, this pathbreaking book will be warmly welcomed by in-house counsel and law firms advising cross-border investors and firms; nongovernmental organizations involved in policy analysis and issue advocacy; researchers working on technical areas of international tax law; and lawyers interested in international policymaking, including the creation and diffusion of consensus-based fiscal and related regulatory norms across jurisdictions of differing development levels.

Handbook of Research on Theory and Practice of Financial Crimes

Author : Rafay, Abdul
Publisher : IGI Global
Page : 650 pages
File Size : 18,74 MB
Release : 2021-03-18
Category : True Crime
ISBN : 1799855694

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Black money and financial crime are emerging global phenomena. During the last few decades, corrupt financial practices were increasingly being monitored in many countries around the globe. Among a large number of problems is a lack of general awareness about all these issues among various stakeholders including researchers and practitioners. The Handbook of Research on Theory and Practice of Financial Crimes is a critical scholarly research publication that provides comprehensive research on all aspects of black money and financial crime in individual, organizational, and societal experiences. The book further examines the implications of white-collar crime and practices to enhance forensic audits on financial fraud and the effects on tax enforcement. Featuring a wide range of topics such as ethical leadership, cybercrime, and blockchain, this book is ideal for policymakers, academicians, business professionals, managers, IT specialists, researchers, and students.

Fiscal Regimes for Extractive Industries—Design and Implementation

Author : International Monetary Fund. Fiscal Affairs Dept.
Publisher : International Monetary Fund
Page : 82 pages
File Size : 41,74 MB
Release : 2012-08-16
Category : Business & Economics
ISBN : 1498340067

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Better designed and implemented fiscal regimes for oil, gas, and mining can make a substantial contribution to the revenue needs of many developing countries while ensuring an attractive return for investors, according to a new policy paper from the International Monetary Fund. Revenues from extractive industries (EIs) have major macroeconomic implications. The EIs account for over half of government revenues in many petroleum-rich countries, and for over 20 percent in mining countries. About one-third of IMF member countries find (or could find) resource revenues “macro-critical” – especially with large numbers of recent new discoveries and planned oil, gas, and mining developments. IMF policy advice and technical assistance in the field has massively expanded in recent years – driven by demand from member countries and supported by increased donor finance. The paper sets out the analytical framework underpinning, and key elements of, the country-specific advice given. Also available in Arabic: ????? ??????? ?????? ???????? ???????????: ??????? ???????? Also available in French: Régimes fiscaux des industries extractives: conception et application Also available in Spanish: Regímenes fiscales de las industrias extractivas: Diseño y aplicación

A Research Agenda for Tax Law

Author : Parada, Leopoldo
Publisher : Edward Elgar Publishing
Page : 233 pages
File Size : 22,59 MB
Release : 2022-10-11
Category : Law
ISBN : 1800885849

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This Research Agenda considers the future direction of research in tax law, channeling creative thinking from leading tax scholars around the world who explore potential routes for further development in both traditional and more unconventional areas of tax law.