Border Carbon Adjustment Mechanisms (BCAMs) are becoming reality in the EU and elsewhere, and recur—in very different form—in U.S. legislative proposals. But they remain contentious, with features and differences that leave the underlying welfare rationale and implications unclear. Exploring...

The international tax framework involves the interaction of domestic laws and international tax treaty obligations. The major concern faced by this framework is the distribution of the right to tax a particular country. Multi-national enterprises use different tax planning techniques to take...

The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting...

In Bezug auf wesentliche Beteiligungen an Kapitalgesellschaften sieht das deutsche Steuerrecht in 6 AStG die sog. Wegzugsbesteuerung vor, um die Besteuerung stiller Reserven sicherzustellen. Die Norm kommt vor allem bei einem Wegzug eines bislang unbeschränkt Steuerpflichtigen und dem damit...

Die Hinzurechnungsbesteuerung ist seit 1972 eine bekannte Maßnahme des nationalen Steuerrechts, um die rein künstliche Gewinnverlagerung ins Ausland zu vermeiden. Trotz ihres stolzen Alters hat die Diskussion um die Hinzurechnungsbesteuerung infolge der Reform der nationalen Regelungen durch...

The standard theory of trade reform uses a passive government budget constraint, in which changes in tariff revenue are offset by changes in lump sum transfers. This paper offers a general framework for the analysis of trade reform when the government budget constraint is active, meaning that...

The integration of world capital markets carries important implications for the design and impact of tax policies. This paper evaluates research findings on international taxation, drawing attention to connections and inconsistencies between theoretical and empirical observations. Diamond and...

According to plans put forward by the OECD/G20 Inclusive Framework on BEPS, a share of residual profit earned by eligible MNEs is to be taxed by market jurisdictions. For this purpose, revenue-based formulaic apportionment of residual profit is proposed. This note argues against the use of a...

The paper evaluates the working of German CFC rules that restrict the use of foreign subsidiaries located in low-tax countries to shelter passive investment income from home taxation. While passive investments make up a significant fraction of German outbound FDI, we find that German CFC rules...

We analyse tax competition with corporate income taxes in a common market where tax revenues are allocated according to an apportionment formula. Generally, tax competition is sharper (i.e., equilibrium tax rates are lower) the more tax-elastic is the apportionment formula. This depends on the...

The paper analyses the gains from trade in distortionary tax revenue between countries, focusing on the case where lump-sum revenue transfers are restricted. In this case, trade taxes can be used to transfer government revenue between countries, and such taxes will typically be used in...

The European Commission recently endorsed a future company tax policy that would allow companies to consolidate their tax bases and apportion the income across the EU using an allocation mechanism. This policy would replace the separate accounting method with formula apportionment of EU group...

This paper demonstrates that under conditions of imperfect (oligopolistic) competition, a transition from separate accounting (SA) to formula apportionment (FA) does not eliminate the problem of profit shifting via transfer pricing. In particular, if affiliates of a multinational firm face...

This paper addresses a key but neglected task in the theory of international taxation, lent increased urgency by growing awareness of the potential gains from tax coordination: the characterization of Pareto-efficient international tax regimes. It shows that the Diamond-Mirrlees theorem on the...

Tax haven countries offer foreign investors low tax rates and other tax features designed to attract investment and thereby stimulate economic activity. Major tax havens have less than one percent of the world's population (outside the United States), and 2.3 percent of world GDP, but host 5.7...

For many emerging and developing economies, it is exceedingly difficult to constrain residents from evading tax liability on income from capital, whether earned domestically or abroad. Meanwhile, an international regime for combatting offshore tax evasion is emerging, and the form of the new...

1. Introduction -- 2. Principles -- 3. Context -- 4. Variability -- 5. The Pace of Change -- 6. Tax Relief at Source -- 7. Quick Refunds -- 8. Standard Refunds -- 9. Reporting -- 10. Governance & Enforcement -- 11. United States of America -- 12. 871(m), 1446(a) and 1446(f) Withholding -- 13. EU...

This book chapter is part of an analysis of European Community (EC) law as it may apply to taxpayers who are resident or nationals of countries that are not EC members (third states), specifically in the field of tax law. The chapter addresses the relation between South African and EC tax law....

Using perfectly competitive, general equilibrium models of international trade, specific import tariffs, specific export taxes, and ad valorem trade taxes are compared in a trade war. A trade war is modelled as a NE in trade policies, where each country can choose to use ad valorem trade taxes...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...

Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...

This paper studies the relationship between trade tax and domestic tax reforms and poverty in developing countries, and explores whether the role of public goods provision matters in this relationship. Using a sample of 91 developing countries for the 1980-2016 period, I model the trade tax...

We analyze the dynamic macroeconomic effects of border adjustment taxes, both when they are a feature of corporate tax reform (C-BAT) and for the case of value added taxes (VAT). Our analysis arrives at the following main conclusions. First, C-BAT is unlikely to be neutral at the macroeconomic...

We study the economic effects of unilateral adoption of corporate tax policies that include destination-based taxes and/or cash ow taxes in a heterogeneous agent model in which multinational firms can endogenously shift income between countries using transfer prices. Standard pass through...

The problems of tax evasion and tax avoidance are as old as taxes themselves. Between 2015 and 2016 alone, many U.S. multinational corporations were involved in tax disputes with the European Commission. From a historical perspective, these disputes are unprecedented as they have resulted in...

We examine how U.S. individuals respond to regulation intended to reduce offshore tax evasion. The Foreign Account Tax Compliance Act (FATCA) requires foreign financial institutions to report information to the U.S. government regarding U.S. account holders. We first document a $7.8 billion to...

We analyze the dynamic macroeconomic effects of border adjustment taxes, both when they are a feature of corporate tax reform (C-BAT) and for the case of value added taxes (VAT). Our analysis arrives at the following main conclusions. First, C-BAT is unlikely to be neutral at the macroeconomic...