A Destination-Based Allowance for Corporate Equity
A Destination-Based Allowance for Corporate Equity

Author: Shafik Hebous

Publisher: International Monetary Fund

Published: 2018-11-08

Total Pages: 26

ISBN-13: 148438413X

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Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.

A Destination-Based Allowance for Corporate Equity
A Destination-Based Allowance for Corporate Equity

Author: Shafik Hebous

Publisher: International Monetary Fund

Published: 2018-11-08

Total Pages: 26

ISBN-13: 1484381904

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Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.

Tax Policy, Leverage and Macroeconomic Stability
Tax Policy, Leverage and Macroeconomic Stability

Author: International Monetary Fund. Fiscal Affairs Dept.

Publisher: International Monetary Fund

Published: 2016-12-10

Total Pages: 78

ISBN-13: 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.

Brazil: Tax Expenditure Rationalization Within Broader Tax Reform
Brazil: Tax Expenditure Rationalization Within Broader Tax Reform

Author: Maria Delgado Coelho

Publisher: International Monetary Fund

Published: 2021-09-24

Total Pages: 46

ISBN-13: 1513596624

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The excessive complexity and burden of the Brazilian tax system, riddled by cumulative indirect taxes and heavy payroll contributions, have led to an accumulation of fiscal incentives aimed at reducing its burden on taxpayers and productive activities. Federal and subnational tax expenditures currently stand at over 5 percent of GDP. Rationalizing them can only be comprehensively feasible in the context of a broader sequenced tax reform, and could reduce resource misallocation and income inequality, as well as provide new revenues.

The X Tax in the World Economy
The X Tax in the World Economy

Author: David F. Bradford

Publisher: A E I Press

Published: 2004

Total Pages: 68

ISBN-13:

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This study explores how the tax design called the X tax could alleviate the complexities and avoidance opportunities plaguing the existing U.S. system for taxing international business income.

No Business Taxation Without Model Representation
No Business Taxation Without Model Representation

Author: Benjamin Carton

Publisher: International Monetary Fund

Published: 2017-11-17

Total Pages: 61

ISBN-13: 1484326016

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The Global Integrated Monetary and Fiscal model (GIMF) is a multi-region, forward-looking, DSGE model developed at the International Monetary Fund for policy analysis and international economic research. This paper documents the incorporation of corporate income, cash-flow and destination based cash-flow taxes into the model. The analysis presented considers the transmission mechanism of these taxes and details how financial frictions interact with each of the taxes.

Corporate Taxation in the Global Economy
Corporate Taxation in the Global Economy

Author: International Monetary Fund. Fiscal Affairs Dept.

Publisher: International Monetary Fund

Published: 2019-03-10

Total Pages: 91

ISBN-13: 1498302254

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The policy paper Corporate Taxation in the Global Economy stresses the need to maintain and build on the progress in international cooperation on tax matters that has been achieved in recent years, and in some respects now appears under stress. With special attention to the circumstances of developing countries, the paper identifies and discusses various options currently under discussion for the international tax system to ensure that countries, and in particular low-income countries, can continue to collect corporate tax revenues from multinational activities.

Studies in the History of Tax Law, Volume 11
Studies in the History of Tax Law, Volume 11

Author: Peter Harris

Publisher: Bloomsbury Publishing

Published: 2023-09-21

Total Pages: 529

ISBN-13: 1509963286

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This book is a continuation of the prestigious series which is drawn from the papers of the biennial Cambridge Tax Law History Conference. The authors are a mix of academics and senior tax professionals from the judiciary and practice with representatives from 9 countries. The series continues to investigate current tax policy debates in an historical context. The papers fall within 3 basic categories: 1. UK and Irish tax, looking at a variety of topics such as tax administration, cases and judges (Whitney, Singer, Viscount Radcliffe), the taxation of royal forests, the taxation of spirits, and income tax transition in the Irish Free State; 2. International taxation, with chapters on the role of international organisations (OECD, League of Nations) and on South Africa's early attempts to address double taxation (tax treaties); and 3. Non-UK tax systems, including chapters on the legacy of colonial influence (Dutch East Indies), early developments in China, New Zealand, and the USA, an influential Canadian report (Carter Commission), development of the GAAR in Scandanavia, and the receipt of Roman tax law in Europe.

Exploring Residual Profit Allocation
Exploring Residual Profit Allocation

Author: Sebastian Beer

Publisher: International Monetary Fund

Published: 2020-02-28

Total Pages: 51

ISBN-13: 1513528327

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Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.