Corporate Income Tax Harmonization and Capital Allocation


Book Description

The IMF Working Papers series is designed to make IMF staff research available to a wide audience. Almost 300 Working Papers are released each year, covering a wide range of theoretical and analytical topics, including balance of payments, monetary and fiscal issues, global liquidity, and national and international economic developments.







The Role of Allocation in a Globalized Corporate Income Tax


Book Description

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.




Reforming Capital Income Taxation


Book Description

This book surveys the theoretical issues that characterize the problem of reforming capital income taxes in an open economy. It explores the tax incentives and disincentives to investment in an open economy framework allowing cross-border portfolio and direct investment.




Corporate Income Tax Harmonization in the European Union


Book Description

Through the arguments for corporate tax harmonization in the EU and describing the current stage of this process, the legislative rules which are insufficient to solve the many problems implied by the proper functioning of the Single Market, are revealed. The book also exposes the issues involved in the consolidation of the corporate tax base.







Corporate Tax Reform: From Income to Cash Flow Taxes


Book Description

This paper uses a multi-region, forward-looking, DSGE model to estimate the macroeconomic impact of a tax reform that replaces a corporate income tax (CIT) with a destination-based cash-flow tax (DBCFT). Two key channels are at play. The first channel is the shift from an income tax to a cash-flow tax. This channel induces the corporate sector to invest more, boosting long-run potential output, GDP and consumption, but crowding out consumption in the short run as households save to build up the capital stock. The second channel is the shift from a taxable base that comprises domestic and foreign revenues, to one where only domestic revenues enter. This leads to an appreciation of the currency to offset the competitiveness boost afforded by the tax and maintain domestic investment-saving equilibrium. The paper demonstrates that spillover effects from the tax reform are positive in the long run as other countries’ exports benefit from additional investment in the country undertaking the reform and other countries’ domestic demand benefits from improved terms of trade. The paper also shows that there are substantial benefits when all countries undertake the reform. Finally, the paper demonstrates that in the presence of financial frictions, corporate debt declines under the tax reform as firms are no longer able to deduct interest expenses from their profits. In this case, the tax shifting results in an increase in the corporate risk premia, a near-term decline in output, and a smaller long-run increase in GDP.




Formulary Apportionment for the Internal Market


Book Description

Since its Company Tax Communication of 2001, the European Commission has been promoting a comprehensive harmonization of corporation taxes within the Internal Market on the basis of consolidation and formulary apportionment of the profits of cross-border enterprises, both in the form of a Home State Taxation (HST) and of the Common Consolidated Corporate Tax Base. This study assesses whether this approach represents a viable alternative to the arm's length standard currently applied in international tax law. The study comprises four parts. First, a theoretical concept of formulary apportionment is presented, followed by an evaluation of the practical experiences of four jurisdictions (United States, Canada, Switzerland and Germany) with formulary apportionment at the subnational level. Next, a proposal for harmonization on the basis of consolidation and apportionment is developed, and the book concludes with an overall analysis of the merits and drawbacks of the proposed model for harmonization.




Financial Markets and Capital Income Taxation in a Global Economy


Book Description

The book describes the developments and the evidence, the problems and the interrelationships among problems, the outlook, and the intricate balance between the national and the international dimensions of the policy issues faced by tax administrations in OECD countries in the field of financial markets and capital income taxation in the wake of profound technological change and market globalization.The book provides a broad perspective of the problems, comparing thoughts on how the problems may be best dealt with, and using lessons from experience with theoretical and policy developments in a number of countries including the EU, North America and Australia.The book focuses on the following topics: bull; falling barriers, increased capital mobility, and the challenges of capital market globalization bull; the implications, for capital income taxation, of technological innovation and new financial products bull; tax distortions and international market pressures for national tax system conformity bull; questions of national tax sovereignty and the constraints imposed on governments by tax competition bull; the growing need for tax cooperation bull; emerging national and international capital taxation issues, including the premise that international cooperation may be key to solving, or at least alleviating, the existing and predicted tax problems.