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Author: Maarten De Wilde Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
How should Europe respond to society's calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the CCTB/CCCTB draft directives into a new system of international taxation, i.e. a unitary taxation model for taxing the worldwide economic profits of multinationals, using a destination-based apportionment formula (CCCTB 2.0) to apportion the tax base to countries both within and outside the European Union. Under such a system, it would be up to the EU Member States themselves to determine the rate applying to the tax base apportioned to them. This would take tax out of the equation in the case of marginal financing and investment decisions, while also curtailing its influence on investment location decisions and, at the same time, making 'gaming the system' more difficult. EU Member States would, in turn, regain their autonomy to set their corporate tax rates at the levels they regard as appropriate, while the proposed model would also end the 'race to the bottom' within the European Union. If the European Union were to be the first mover, self-interest would prompt other countries and regions to follow its lead. The resulting production location neutrality would encourage international businesses to embrace the model and lobby for transition as rapidly as possible. Driven by self-interest and competitive responses, such a move could initiate a transition to the worldwide adoption of destination-based taxation of excess earnings - in other words, harmonization through competition. As the innovator, the European Union would enjoy the greatest economic benefit during the transitional period, when countries' profit tax systems would be evolving towards an equilibrium in which destination-based tax would become the new global standard. The final destination would be a new destination-based company tax paradigm operating both neutrally and non-discriminatorily on the supply side. That would produce a result that would not only be fair, but would also - and primarily - provide a systemic and economically efficient solution for the international problem of BEPS.Full-text Paper.
Author: Maarten De Wilde Publisher: ISBN: Category : Languages : en Pages : 0
Book Description
How should Europe respond to society's calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the CCTB/CCCTB draft directives into a new system of international taxation, i.e. a unitary taxation model for taxing the worldwide economic profits of multinationals, using a destination-based apportionment formula (CCCTB 2.0) to apportion the tax base to countries both within and outside the European Union. Under such a system, it would be up to the EU Member States themselves to determine the rate applying to the tax base apportioned to them. This would take tax out of the equation in the case of marginal financing and investment decisions, while also curtailing its influence on investment location decisions and, at the same time, making 'gaming the system' more difficult. EU Member States would, in turn, regain their autonomy to set their corporate tax rates at the levels they regard as appropriate, while the proposed model would also end the 'race to the bottom' within the European Union. If the European Union were to be the first mover, self-interest would prompt other countries and regions to follow its lead. The resulting production location neutrality would encourage international businesses to embrace the model and lobby for transition as rapidly as possible. Driven by self-interest and competitive responses, such a move could initiate a transition to the worldwide adoption of destination-based taxation of excess earnings - in other words, harmonization through competition. As the innovator, the European Union would enjoy the greatest economic benefit during the transitional period, when countries' profit tax systems would be evolving towards an equilibrium in which destination-based tax would become the new global standard. The final destination would be a new destination-based company tax paradigm operating both neutrally and non-discriminatorily on the supply side. That would produce a result that would not only be fair, but would also - and primarily - provide a systemic and economically efficient solution for the international problem of BEPS.Full-text Paper.
Author: M.F. de Wilde Publisher: ISBN: Category : Languages : en Pages :
Book Description
How should Europe respond to society's calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the CCTB/CCCTB draft directives into a new system of international taxation, i.e. a unitary taxation model for taxing the worldwide economic profits of multinationals, using a destination-based apportionment formula (CCCTB 2.0) to apportion the tax base to countries both within and outside the European Union. Under such a system, it would be up to the EU Member States themselves to determine the rate applying to the tax base apportioned to them. This would take tax out of the equation in the case of marginal financing and investment decisions, while also curtailing its influence on investment location decisions and, at the same time, making 'gaming the system' more difficult. EU Member States would, in turn, regain their autonomy to set their corporate tax rates at the levels they regard as appropriate, while the proposed model would also end the 'race to the bottom' within the European Union. If the European Union were to be the first mover, self-interest would prompt other countries and regions to follow its lead. The resulting production location neutrality would encourage international businesses to embrace the model and lobby for transition as rapidly as possible. Driven by self-interest and competitive responses, such a move could initiate a transition to the worldwide adoption of destination-based taxation of excess earnings - in other words, harmonization through competition. As the innovator, the European Union would enjoy the greatest economic benefit during the transitional period, when countries' profit tax systems would be evolving towards an equilibrium in which destination-based tax would become the new global standard. The final destination would be a new destination-based company tax paradigm operating both neutrally and non-discriminatorily on the supply side. That would produce a result that would not only be fair, but would also - and primarily - provide a systemic and economically efficient solution for the international problem of BEPS.
Author: Pernille Stordrange Publisher: GRIN Verlag ISBN: 3656200106 Category : Political Science Languages : en Pages : 29
Book Description
Seminar paper from the year 2012 in the subject Politics - International Politics - Topic: European Union, grade: A, BI Norwegian Business School (Public governance), course: EU Policy Process, language: English, abstract: In this paper I chronologically go through the policy process towards a harmonised corporate income tax in the EU member states. By using Jenkins-Smith and Sabatier's advocacy coalition framework (ACF) I evaluate how events internal and external to the EU, as well as policy-oriented learning have brought the process forward and caused policy change. I also explain how the lack of favourable conditions has caused stalemate and lack of progress. I find that changing socio-economic conditions have facilitated and hampered the policy process and that macroeconomic conditions have affected member states willingness to implement coordinating measures. Other determinants of change are internal developments in the EU such as enlargements, ECJ jurisprudence or change in political leadership. Over the time period under study, the European Commission, as the agenda-setter in the EU has learned from previous failures and new scientific information and altered its strategy along the way. Member states have also over time changed their view on the EU in general and corporate income tax harmonisation in particular. The outcome of the EC's efforts over the years has been varying, and the policy process has proceeded in fits and starts. So far, the EC has achieved some degree of coordination, but not harmonisation of corporate income tax systems. What the future brings depends on the variables discussed throughout the paper.
Author: Krister Andersson Publisher: Springer Science & Business Media ISBN: 3540707115 Category : Business & Economics Languages : en Pages : 264
Book Description
The book is dedicated to the question of how much room for national tax policy Member States of the European Union will be able to maintain in the future. It focuses on the possibilities Member States have and the limits they face, such as the need to finance the welfare state or limits of European and International Law. The research question is looked at from different angles. Economic as well as legal aspects are included.
Author: Michael Lang Publisher: Edward Elgar Publishing ISBN: 9781782545415 Category : Corporations Languages : en Pages : 0
Book Description
This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies. The book considers the impact of the CCCTB from the perspective of non-EU-based enterprises that are carrying on business in the EU through the operation of branches or subsidiaries in member states. It incorporates the perspectives of leading scholars from all over Europe as well as from third countries such as the United States, and provides in-depth analysis of the key aspects which would affect third countries, such as: withholding taxation, taxation of transparent entities, and transfer of assets to third countries. Corporate Income Taxation in Europe will provide essential insights to academics, practitioners and policymakers in the field of taxation. It will also interest those looking ahead to future tax reforms in the EU, or considering how a similar model may be applied elsewhere. Contributors K. Andersson, K. Becker, Y. Brauner, J. Englisch, D. Gutmann, C.-A. Helleputte, W. Hellerstein, C. HJI Panayi, C. Kaeser, M.A. Kane, T. Keijzer, E.C.C.M. Kemmeren, R. Lyal, G. Maisto, P. Pistone, R. Seer, D.S. Smit, C. Spengel, J. van de Streek, E. Traversa, D. Weber
Author: Publisher: ISBN: 9789283045571 Category : Languages : en Pages :
Book Description
Taxation in the EU must encourage domestic and cross-border business activities, job creation, investments, entrepreneurship and economic growth. - Taxation rules need to be clear and simple in order to avoid divergent interpretations and, as a result, costly disputes and double taxation. - Open, transparent tax competition between EU countries is crucial for further economic growth. - Corporate taxes generally create numerous and severe economic distortions and are to a large extent shifted to workers, consumers and suppliers. - Corporate income tax should be based on profit and not on revenue. In general, the corporate tax rate should be low and the base should be broad. - Lowering the corporate tax rate results in more investments and more taxable revenue. Economic data show that lowering the tax rate is often self-financing because of the resulting larger tax base. More investment opportunities become economically viable when the tax rate is reduced and are therefore more likely to be taken up. - Corporate tax revenue has been a stable contributor to overall tax revenue for the last 40 years – around 2.5% of GDP. - Corporations pay many other taxes, environmental levies, taxes on inputs such as energy, taxes on transportation, property taxes etc. In addition, companies act as an unpaid tax collector for governments.
Author: Richard Krever Publisher: Kluwer Law International B.V. ISBN: 9403506156 Category : Law Languages : en Pages : 307
Book Description
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: Maarten De Wilde
Author: Maarten De Wilde
Author: M.F. de Wilde
Author: Pernille Stordrange
Author: Krister Andersson
Author: Harry Huizinga
Author: Michael Lang
Author: Bernd Genser
Author: 
Author: Michael Lang
Author: Richard Krever