Download or read book Tax Competition and Tax Coordination in Aggressive Tax Planning a False Dichotomy written by P. Piantavigna and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article addresses a massive topic: tax competition and trends in aggressive tax planning matters. In particular, the article aims at demonstrating how the concepts of "tax competition" and "tax coordination" must be rephrased after the introduction of the notion of "aggressive tax planning" in order to be acknowledged in the new (global) operating environment. Even if the concept of "tax competition" cannot be totally formalized or objectified, literature - prior to the BEPS Project - was used to identify it in policies between tax jurisdictions by way of tax incentives and advantages to attract sales, distribution, or headquarter functions of MNEs to locate to a particular country. This phenomenon, labelled as "fair" under the jurisdictional competition theory, emerges as "harmful" insofar as it distorts the location of business and trade, erodes the tax base of other countries (also referred to as contributing to the "race to the bottom") and undermines the fairness, neutrality and broad social acceptance of tax systems generally. Following the introduction of the (rather new) notion of "aggressive tax planning", it is examined whether the scope of the harmful tax competition may be extended and - as a result - whether it requires more integrated tax coordination at international level. The answer to that question is particularly problematic, and it also has consistent implications in the EU area, where tax competition plays a fundamental role in economic and monetary policies. In this article, the author argues that, to the extent that national tax-competitive measures fulfil the artificiality test implied in the concept of aggressive tax planning as elaborated by the OECD and embodied by EU law, countries may (fairly) compete and - at the same time - be coordinated in the fight against BEPS behaviours. Indeed, the concept of aggressive tax planning represents the most appropriate balancing instrument to satisfy the need for states to protect their tax revenues and to preserve the right of sovereign governments to introduce favourable regimes to attract investments and taxable profits.
Download or read book Tax Competition and Tax Coordination in Aggressive Tax Planning written by Paolo Piantavigna and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This article addresses a massive topic: tax competition and trends in aggressive tax planning matters. In particular, the article aims at demonstrating how the concepts of "tax competition" and "tax coordination" must be rephrased after the introduction of the notion of "aggressive tax planning" in order to be acknowledged in the new (global) operating environment. Even if the concept of "tax competition" cannot be totally formalized or objectified, literature - prior to the BEPS Project - was used to identify it in policies between tax jurisdictions by way of tax incentives and advantages to attract sales, distribution, or headquarter functions of MNEs to locate to a particular country. This phenomenon, labelled as "fair" under the jurisdictional competition theory, emerges as "harmful" insofar as it distorts the location of business and trade, erodes the tax base of other countries (also referred to as contributing to the "race to the bottom") and undermines the fairness, neutrality and broad social acceptance of tax systems generally. Following the introduction of the (rather new) notion of "aggressive tax planning", it is examined whether the scope of the harmful tax competition may be extended and - as a result - whether it requires more integrated tax coordination at international level. The answer to that question is particularly problematic, and it also has consistent implications in the EU area, where tax competition plays a fundamental role in economic and monetary policies. In this article, the author argues that, to the extent that national tax-competitive measures fulfil the artificiality test implied in the concept of aggressive tax planning as elaborated by the OECD and embodied by EU law, countries may (fairly) compete and - at the same time - be coordinated in the fight against BEPS behaviours. Indeed, the concept of aggressive tax planning represents the most appropriate balancing instrument to satisfy the need for states to protect their tax revenues and to preserve the right of sovereign governments to introduce favourable regimes to attract investments and taxable profits.Full-text Paper.
Download or read book Coordination and Cooperation written by Brigitte Alepin and published by Kluwer Law International B.V.. This book was released on 2021-11-25 with total page 301 pages. Available in PDF, EPUB and Kindle. Book excerpt: Series on International Taxation #81 The tax landscape today looks dramatically different from how it appeared even a generation ago. Ongoing sweeping changes in information technologies, massive economic downturns, unforeseen catastrophes such as the global pandemic that hit the world in 2020, and ever more sophisticated methods of tax evasion and avoidance are only some of the factors that have perplexed and even confounded tax authorities. This important book provides a comprehensive overview of the global tax challenges confronting tax policy today, with insightful contributions by both well-known tax experts and fresh new voices in the field. The authors address such critical issues as the following: international tax reform initiatives; effects of climate change; tax justice in times of crisis; international tax cooperation; taxing multinationals; role of tax havens; participation and collaboration of developing countries; the growing presence of artificial intelligence and robots; prospects for a green economic recovery; and tax ethics and social inclusiveness. The contributions originated with the groundbreaking tax summit TaxCOOP2020, held online at the peak of the Covid-19 pandemic in October 2020. At a time when tax policy seems poised at the dawn of a fundamental transformation, this inestimable volume will be welcomed by tax practitioners and academics, concerned government officials, businesspeople, international organizations, and non-governmental organizations (NGOs), all of whom will here have access to a variety of points of view and innovative approaches to the future direction of taxation.
Download or read book Towards a Neutral Formulary Apportionment System in Regional Integration written by Shu-Chien Chen and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 471 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.
Download or read book Hybrid Financial Instruments Double Non Taxation and Linking Rules written by Félix Daniel Martínez Laguna and published by Kluwer Law International B.V.. This book was released on 2019-06-12 with total page 685 pages. Available in PDF, EPUB and Kindle. Book excerpt: Hybrid Financial Instruments, Double Non-taxation and Linking Rules Félix Daniel Martínez Laguna Hybrid financial instruments (HFIs) are widespread ordinary financial instruments that combine debt and equity features in their terms and design and may lead to double non-taxation across borders. This important book provides a deeply informed and critical analysis and guide to the “linking rules” developed to combat double non-taxation stemming from HFIs within the framework of the Base Erosion and Profit Shifting project of the Organisation for Economic Co-operation and Development (OECD) and the anti-avoidance initiatives of the European Union (EU). These complex rules have now become essential in international taxation. The book deals incisively with crucial theoretical and practical issues as the following: Economic and legal reasons for financing business activity through debt instruments, equity instruments and/or HFIs. Qualification of financial instruments from different perspectives such as economics, corporate finance, corporate law, financial accounting law, regulatory law and tax law and their interrelation. The concept of double non-taxation as a mere outcome of parallel exercises of sovereignty by different states and the role it plays within the international debate. The concepts of tax planning, tax avoidance and the misleading concept of aggressive tax planning within a tax competition international scenario and their relation with HFIs. Comprehensive policy, legal and technical detail and explanation of the linking rules proposed by the OECD (i.e., BEPS Project Action 2) and the EU (e.g., Anti-Tax Avoidance Directive). The (in)compatibility of linking rules with existing tax treaty rules and EU primary law. The author refers throughout to relevant model convention provisions, EU case law and a vast number of references of official documentation and literature. With its detailed attention to the concept and legal nature of HFIs and double non-taxation, the critical and comprehensive analysis of the linking rules developed by the OECD and the EU, this provocative book allows to reconsider the legality of these linking rules and will quickly become a much-used problem-solving resource for policymakers, tax practitioners, tax authorities and tax academics. This book allows to rethink whether linking rules relate to a solution or create actual legal issues.
Download or read book Complexity and Sustainability in Megaprojects written by Edoardo Favari and published by Springer Nature. This book was released on 2023-05-31 with total page 341 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book showcases the discussion about megaprojects carried out at the MeRIT (Megaproject Research Interdisciplinary Team) workshop 2022: the crisis, discontinuity, rising prices, and supply chains disruption force radical reflection for those involved in megaprojects. It raises a modern-day challenge, the creation of value for stakeholders. Indeed, the aim of the volume is to encourage readers to think more broadly, articulately and less stringently than the mainstream claims. There is a need to design, implement, and manage megaprojects by abandoning the old paradigm that leveraged solely on time and cost. We need to move beyond that by going to explore the value generated, the positive impact on people, communities and territories. Economic, social and environmental sustainability takes on a new and broader articulation: issues of the circular economy applied to megaprojects are addressed and ample space is ensured for the inclusion of social needs in current practices.
Download or read book Tax Us If You Can written by Tax Justice Network-Africa and published by Fahamu/Pambazuka. This book was released on 2011-10-20 with total page 95 pages. Available in PDF, EPUB and Kindle. Book excerpt: This short introduction to issues of tax justice explains the meaning and causes of tax injustice and offers options for a better future. Providing insight into the specific failures of Africa s tax systemand the associated problems of capital flight, tax evasion, tax avoidance, and tax competitionthis book explores the role of governments, parliaments, and taxpayers, and asks how stakeholders can help achieve tax justice. Arguing that tax revenues are essential for establishing independent states of free citizens, it demonstrates how the tax consensus promoted by multilateral agencies, such as the World Bank and the International Monetary Fund, has influenced tax policy in Africa and led to a reduction in government revenues in many countries. "
Download or read book Global Tax Governance written by Peter Dietsch and published by . This book was released on 2016-02-03 with total page 382 pages. Available in PDF, EPUB and Kindle. Book excerpt: High-profile scandals and increasing public debt after the financial crisis have put international taxation high on the political agenda. This book offers a rare combination of empirical analysis with normative and institutional proposals for global tax governance.
Download or read book Dimensions of Tax Design written by James A. Mirrlees and published by Oxford University Press. This book was released on 2010-04-29 with total page 1360 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Review was chaired by Nobel Laureate Professor Sir James Mirrlees of the University of Cambridge and the Chinese University of Hong Kong. --
Download or read book Mining Royalties written by and published by World Bank Publications. This book was released on 2006-01-01 with total page 320 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book contains a wealth of information and analysis relating to mineral royalties. Primary information includes royalty legislation from over forty nations. Analysis is comprehensive and addresses issues of importance to diverse stakeholders including government policymakers, tax administrators, society, local communities and mining companies. Extensive footnotes and citations provide a valuable resource for researchers.
Download or read book The Future of Multilateralism written by Madeleine O. Hosli and published by Rowman & Littlefield. This book was released on 2021-07-29 with total page 329 pages. Available in PDF, EPUB and Kindle. Book excerpt: The Future of Multilateralism addresses current challenges and future perspectives of international and regional organizations. It aims to uncover how stable the foundations of global cooperation really are, particularly in the light of the latest unilateral and protectionist practices of international players and challenges related to COVID-19. The post–World War II global order was built on the foundations of multilateral cooperation. The establishment of international institutions is aimed at avoiding another widespread collision like the two World Wars and to ensure peace and prosperity. Hence, the multilateral system was viewed as an effective mechanism in dealing and resolving various challenges at an international or a regional level. Given the effects of COVID-19 on the global, regional, state, and individual levels are so recent, very little research has been conducted to understand the challenges many multilateral institutions are facing due to the pandemic. This book uncovers the future of such organizations and prospects for the multilateral system, of which they constitute the building blocks, in view of recent trends and developments.
Download or read book Financing Metropolitan Governments in Developing Countries written by Roy W. Bahl and published by Lincoln Inst of Land Policy. This book was released on 2013 with total page 430 pages. Available in PDF, EPUB and Kindle. Book excerpt: The economic activity that drives growth in developing countries is heavily concentrated in cities. Catchphrases such as “metropolitan areas are the engines that pull the national economy” turn out to be fairly accurate. But the same advantages of metropolitan areas that draw investment also draw migrants who need jobs and housing, lead to demands for better infrastructure and social services, and result in increased congestion, environmental harm, and social problems. The challenges for metropolitan public finance are to capture a share of the economic growth to adequately finance new and growing expenditures and to organize governance so that services can be delivered in a cost-effective way, giving the local population a voice in fiscal decision making. At the same time, care must be taken to avoid overregulation and overtaxation, which will hamper the now quite mobile economic engine of private investment and entrepreneurial initiative. Metropolitan planning has become a reality in most large urban areas, even though the planning agencies are often ineffective in moving things forward and in linking their plans with the fiscal and financial realities of metropolitan government. A growing number of success stories in metropolitan finance and management, together with accumulated experience and proper efforts and support, could be extended to a broader array of forward-looking programs to address the growing public service needs of metropolitan-area populations. Nevertheless, sweeping metropolitan-area fiscal reforms have been few and far between; the urban policy reform agenda is still a long one; and there is a reasonable prospect that closing the gaps between what we know how to do and what is actually being done will continue to be difficult and slow. This book identifies the most important issues in metropolitan governance and finance in developing countries, describes the practice, explores the gap between practice and what theory suggests should be done, and lays out the reform paths that might be considered. Part of the solution will rest in rethinking expenditure assignments and instruments of finance. The “right” approach also will depend on the flexibility of political leaders to relinquish some control in order to find a better solution to the metropolitan finance problem.
Download or read book Global Trends 2040 written by National Intelligence Council and published by Cosimo Reports. This book was released on 2021-03 with total page 158 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The ongoing COVID-19 pandemic marks the most significant, singular global disruption since World War II, with health, economic, political, and security implications that will ripple for years to come." -Global Trends 2040 (2021) Global Trends 2040-A More Contested World (2021), released by the US National Intelligence Council, is the latest report in its series of reports starting in 1997 about megatrends and the world's future. This report, strongly influenced by the COVID-19 pandemic, paints a bleak picture of the future and describes a contested, fragmented and turbulent world. It specifically discusses the four main trends that will shape tomorrow's world: - Demographics-by 2040, 1.4 billion people will be added mostly in Africa and South Asia. - Economics-increased government debt and concentrated economic power will escalate problems for the poor and middleclass. - Climate-a hotter world will increase water, food, and health insecurity. - Technology-the emergence of new technologies could both solve and cause problems for human life. Students of trends, policymakers, entrepreneurs, academics, journalists and anyone eager for a glimpse into the next decades, will find this report, with colored graphs, essential reading.
Download or read book World Development Report 2019 written by World Bank and published by World Bank Publications. This book was released on 2018-10-31 with total page 148 pages. Available in PDF, EPUB and Kindle. Book excerpt: Work is constantly reshaped by technological progress. New ways of production are adopted, markets expand, and societies evolve. But some changes provoke more attention than others, in part due to the vast uncertainty involved in making predictions about the future. The 2019 World Development Report will study how the nature of work is changing as a result of advances in technology today. Technological progress disrupts existing systems. A new social contract is needed to smooth the transition and guard against rising inequality. Significant investments in human capital throughout a person’s lifecycle are vital to this effort. If workers are to stay competitive against machines they need to train or retool existing skills. A social protection system that includes a minimum basic level of protection for workers and citizens can complement new forms of employment. Improved private sector policies to encourage startup activity and competition can help countries compete in the digital age. Governments also need to ensure that firms pay their fair share of taxes, in part to fund this new social contract. The 2019 World Development Report presents an analysis of these issues based upon the available evidence.
Download or read book Science the Endless Frontier written by Vannevar Bush and published by Princeton University Press. This book was released on 2021-02-02 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The classic case for why government must support science—with a new essay by physicist and former congressman Rush Holt on what democracy needs from science today Science, the Endless Frontier is recognized as the landmark argument for the essential role of science in society and government’s responsibility to support scientific endeavors. First issued when Vannevar Bush was the director of the US Office of Scientific Research and Development during the Second World War, this classic remains vital in making the case that scientific progress is necessary to a nation’s health, security, and prosperity. Bush’s vision set the course for US science policy for more than half a century, building the world’s most productive scientific enterprise. Today, amid a changing funding landscape and challenges to science’s very credibility, Science, the Endless Frontier resonates as a powerful reminder that scientific progress and public well-being alike depend on the successful symbiosis between science and government. This timely new edition presents this iconic text alongside a new companion essay from scientist and former congressman Rush Holt, who offers a brief introduction and consideration of what society needs most from science now. Reflecting on the report’s legacy and relevance along with its limitations, Holt contends that the public’s ability to cope with today’s issues—such as public health, the changing climate and environment, and challenging technologies in modern society—requires a more capacious understanding of what science can contribute. Holt considers how scientists should think of their obligation to society and what the public should demand from science, and he calls for a renewed understanding of science’s value for democracy and society at large. A touchstone for concerned citizens, scientists, and policymakers, Science, the Endless Frontier endures as a passionate articulation of the power and potential of science.
Download or read book Tax Sovereignty in the BEPS Era written by Sergio André Rocha and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 338 pages. Available in PDF, EPUB and Kindle. Book excerpt: The power of a country to freely design its tax system is generally understood to be an integral feature of sovereignty. However, as an inevitable result of globalization and income mobility, one country’s exercise of tax sovereignty often overlaps, interferes with, or even impedes that of another. In this collection of essays, internationally respected practitioners and academics reveal how the OECD’s Base Erosion and Pro t Shifting (BEPS) initiative, although a major step in the right direction, is insuf cient to resolve the tax sovereignty paradox. Each contribution deals with different facets of a single topic: How tax sovereignty is shaped in a post ,BEPS world. The contributors provide in ,depth analysis of such relevant issues as the following: hy multilateral cooperation and soft law consensus are the preferred solutions to a loss of autonomy over national tax policy; – how digital commerce has upended traditional notions of source and residence; – why residence and source continue to be the two essential building blocks of tax sovereignty and the backbone of the international tax system; – how developing countries can take advantage of the new international tax architecture to ensure that their voices are truly shaping the standards; and – transfer pricing reform. Collectively, the authors provide an authoritative commentary on the necessary preconditions for exercising the power to tax in today’s world. Their perspectives and recommendations will prove of great value to all policymakers, legislators, practitioners, and academics in the international taxation arena.
Download or read book Markets in Vice Markets in Virtue written by John Braithwaite and published by Oxford University Press, USA. This book was released on 2005 with total page 262 pages. Available in PDF, EPUB and Kindle. Book excerpt: This sweeping, comparative study of taxation in the United States and Australia shows that even as governments in the Western world have become increasingly sophisticated tax collectors, a competitive and ruthless market in advice on tax avoidance has developed. The same competitive forces in the late twentieth century which have driven down prices and sparked efficiencies in the production of fast food or computer parts have helped stimulate the markets for "bads" like tax shelters and problem gambling. Braithwaite draws the surprising conclusion that effective regulation could actually flip markets in vice to markets of virtue. Essential reading for anyone involved in policy, governance, and regulation, Markets in Vice, Markets in Virtue provides a blueprint for restoring the equity of Western tax systems and a breakthrough theory of how regulators can support markets in virtue and curtail markets in vice.
