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...

This policy note summarises the main findings of our recent research on the effects of labour and corporate taxation on international trade, and discusses their policy implications. The first major finding is that labour taxes do not seem to affect imports, while their effect on exports is...

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...

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...

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...

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...

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...

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....

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...

There is a serious problem in international taxation today. Many United States (U.S.) multinational corporations have moved abroad to take advantage of a lower tax rate in a foreign country. As a consequence, the tax base in the U.S. has been seriously eroded. This practice is known as...

This piece aims to answer two main questions. First, what has been the evolutionary pattern of transfer pricing regulations in Argentina since the inception of corporate income taxation in 1932? Secondly, what is the core dynamic of transfer pricing dispute resolution in Argentina since then?

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...

Zieht ein Gesellschafter eines Familienunternehmens ins außereuropäische Ausland, wird sofort die Wegzugssteuer auf seinen Unternehmensanteil gefordert – in Höhe seines persönlichen Einkommensteuersatzes. Zwar gibt es Regelungen für Stundungen, doch sind diese uneinheitlich und vom...

I analyze the choice between an intercompany loan denominated in the home currency and one denominated in the subsidiary's functional currency. Using US rules for financial accounting and taxes, I model the impact of the loan's currency denomination on a multinational's expected overall tax and...

Cross-border tax evasion has emerged in recent years as a central issue in tax enforcement. Traditionally, the legal regime governing cross-border tax enforcement was based on information exchange upon request. In 2010, the US Congress enacted the Foreign Account Tax Compliance Act (FATCA),...

This article summarises and analyses Australia's treatment of interest expense for tax purposes, with a focus on cross-border interest. It covers the definition of interest for tax purposes, payments equivalent to interest, the circumstances in which interest is deductible to the lender and...

Die Schaffung, Zuordnung und Verwertung von IP-Rechten ist eine der interessantesten Herausforderungen, wenn es um die Steuerplanung geht. Einer Bandbreite attraktiver Gestaltungsmöglichkeiten stehen nicht unerhebliche Risiken und die politische Forderung nach einer verantwortungsvollen...

Der EU-Austritt Großbritanniens und Nordirlands wird rückblickend sicherlich zu einer der größten Herausforderungen der EU werden. Aktuell ist eine große Unsicherheit gegenüber dem Brexit-Ereignis und dessen Auswirkungen auf verschiedene Bereiche zu verzeichnen. Keanu Moseler betrachtet...

We examine the effect of a permanent change to a country corporate income repatriation tax system on corporate financial policies. In 2009 Japan and the U.K. switched from a worldwide to a territorial system for the taxation of repatriated foreign earnings. The new system effectively reduces the...

Current shortfalls in financing required for full achievement of the Millennium Development Goals have led to calls for consideration of novel means of development finance. This Article describes such a novel means of development finance based on a radical rethinking of the typical allocation of...

In recent decades environmental protection and more generally global warming have attracted great political concern. In this respect taxes can be some valid governmental tools to pursue specific environmental purposes, as well as to create incentives to change unsustainable patterns of...

The American Jobs Creation Act (AJCA) significantly lowered US firms' tax cost when accessing their unrepatriated foreign earnings. Using this temporary shock to the cost of internal financing, we examine the role of capital constraints in firms' investment decisions. Controlling for the...