Advanced Introduction to International Tax Law

Advanced Introduction to International Tax Law
By:Reuven S. Avi-Yonah
Published on 2019-04-27 by Edward Elgar Publishing

Elgar Advanced Introductions are stimulating and thoughtful introductions to major fields in the social sciences and law, expertly written by the world's leading scholars.

Designed to be accessible yet rigorous, they offer concise and lucid surveys of the substantive and policy issues associated with discrete subject areas.This second edition of the Advanced Introduction to International Tax Law provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax.

This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.

New to this edition:* New material on the OECD Base Erosion and Profit Shifting (BEPS) project* Coverage of the EU's Anti Tax Avoidance Package* Analysis of the US Tax Cuts and Jobs Act.Key features include: * defines and discusses the main types of jurisdiction to tax* explains in depth both inbound and outbound taxation on both passive and active income* delineates the source of income that is crucial for taxing non-residents and foreign tax credit* discussion of transfer pricing, a variant of source-based taxation that lies at the heart of modern efforts to tax corporations at source* explains how the above elements are influenced by tax treaties and looks at the future of the international tax regime.Composed of concise but insightful chapters, this revised second edition will prove to be a key resource for students of international tax law, as well as for scholars within the fields of tax law, international business law and international commercial law.

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International Corporate Tax Rate Comparisons and Policy Implications

International Corporate Tax Rate Comparisons and Policy Implications
By:Jane G. Gravelle
Published on 2013-01-05 by Createspace Independent Pub

Advocates of cutting corporate tax rates frequently make their argument based on the higher statutory rate in the United States as compared with the rest of the world; they argue that cutting corporate taxes would induce large investment flows into the United States, which would create jobs or expand the taxable income base enough to raise revenue.

President Barack Obama has supported a rate cut if the revenue loss can be offset with corporate base broadening.

Others have urged on one hand, a revenue raising reform, and, on the other, setting deficit concerns aside.

Is the U.S.

tax rate higher than the rest of the world, and what does that difference imply for tax policy? The answer depends, in part, on which tax rates are being compared.

Although the U.S.

statutory tax rate is higher, the average effective rate is about the same, and the marginal rate on new investment is only slightly higher.

The statutory rate differential is relevant for international profit shifting; effective rates are more relevant for firms' investment levels.

The 13.7 percentage point differential in statutory rates (a 39.2% rate for the United States compared with 25.5% in other countries), narrows to about 9 percentage points when tax rates in the rest of the world are weighted to reflect the size of countries' economies.

(The OECD rates fell by slightly over1/2 of a percentage point between 2010 and 2012) Regardless of tax differentials, could a U.S.

rate cut lead to significant economic gains and revenue feedbacks? Because of the factors that constrain capital flows, estimates for a rate cut from 35% to 25% suggest a modest positive effect on wages and output: an eventual one-time increase of less than two-tenths of 1% of output.

Most of this output gain is not an increase in national income because returns to capital imported from abroad belong to foreigners and the returns to U.S.

investment abroad that comes back to the United States are already owned by U.S.

firms.

The revenue cost of such a rate cut is estimated at between $1.2 trillion and $1.5 trillion over the next 10 years.

Revenue feedback effects from increased investment inflows are estimated to reduce those revenue costs by 5%-6%.

Reductions in profit shifting could have larger effects, but even if profit shifting disappeared entirely, it would not likely offset revenue losses.

It seems unlikely that a rate cut to 25% would significantly reduce profit shifting given these transactions are relatively costless and largely constrained by laws, enforcement, and court decisions.

Both output gains and revenue offsets would be reduced if other countries responded to a U.S.

rate cut by reducing their own taxes.

Evidence suggests that the U.S.

rate cut in the Tax Reform Act of 1986 triggered rate cuts in other countries.

It is difficult, although not impossible, to design a reform to lower the corporate tax rate by 10 percentage points that is revenue neutral in the long run.

Standard tax expenditures do not appear adequate for this purpose.

Eliminating one of the largest provisions, accelerated depreciation, gains much more revenue in the short run than in the long run, and a long-run revenue-neutral change would increase the cost of capital.

Other revisions, such as restricting foreign tax credits and interest deductibility or increasing shareholder level taxes, may be required.

This publication focuses on the global issues relating to tax rate differentials between the United States and other countries.

It provides tax rate comparisons; discusses policy implications, including the effect of a corporate rate cut on revenue, output, and national welfare; and discusses the outlook for and consequences of a revenue neutral corporate tax reform.

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100 Million Unnecessary Returns

100 Million Unnecessary Returns
By:Michael J. Graetz
Published on 2008-10-01 by Yale University Press

To most Americans, the United States tax code has become a vast and confounding puzzle.

This text maintains that the US tax code has become a tangle of loopholes, paperwork, and inconsistencies, a massive social programme that fails tests of simplicity and fairness.

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Dynamic Transformation

Dynamic Transformation
By:Gill C. Lim
Published on 1990 by

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Capital Account Liberalization and Corporate Taxes

Capital Account Liberalization and Corporate Taxes
By:Mr. Ben Lockwood
Published on 2003-09-01 by International Monetary Fund

This paper studies whether exchange controls, particularly on the capital account, affect the choice of corporate tax rates, using a panel of 21 OECD countries over the period 1983-99.

It builds on existing literature by (1) using a unique dataset with several different measures of the corporate tax rate calculated from the actual parameters of the tax systems, and (2i) allowing exchange controls to affect the intensity of strategic interaction between countries in setting taxes, as well as the levels of tax they choose.

We find some evidence that (1) the level of a country’s tax, other things equal, is lowered by a unilateral liberalization of exchange controls; and (2) that strategic interaction in taxsetting between countries is increased by liberalization.

These effects are stronger if the country is a high-tax one and if the tax is the statutory or effective average one.

There is also evidence that countries’ own tax rates are reduced by liberalization of exchange controls in other countries.

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International Group Financing and Taxes

International Group Financing and Taxes
By:Christian Massoner
Published on 2012 by

The tax issues around international group financing have continuously been a hot topic in the academia as well as in tax practice over the last years.

The decision between debt and equity financing may significantly affect both a taxpayer's tax burden and the revenues of the countries in which the taxpayer is doing business.

Traditionally, debt financing shifts the tax base from the source country to the residence country, while equity financing has the opposite effect.

Multinational enterprises use intra-group debt and equity financing to realize tax arbitrage in order to reduce their overall tax burden.

Naturally, many countries and tax authorities are focusing on measures that shield their tax revenues from international tax planning.

The master theses contained in this volume examine these issues from a tax treaty law, Community law as well as domestic tax law perspective.

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International VAT/GST Guidelines

International VAT/GST Guidelines
By:OECD
Published on 2017-04-12 by OECD Publishing

The International VAT/GST Guidelines present a set of internationally agreed standards and recommended approaches for the consistent application of VAT to international trade, with a particular focus on trade in services and intangibles.

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OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017

OECD Transfer Pricing Guidelines for Multinational Enterprises and Tax Administrations 2017
By:OECD
Published on 2017-07-10 by OECD Publishing

This consolidated version of the OECD Transfer Pricing Guidelines includes the revised guidance on safe harbours adopted in 2013, as well as the recent amendments made by the Reports on Actions 8-10 and 13 of the BEPS Actions Plan and conforming changes to Chapter IX.

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Tax Management Portfolios

Tax Management Portfolios
By:
Published on 1971* by

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