International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots
Author: Sebastian Beer
Publisher: International Monetary Fund
Total Pages: 45
Release: 2018-07-23
Genre: Business & Economics
ISBN: 1484370538

This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.

Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law

Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law
Author: Savvas Kostikidis
Publisher: Kluwer Law International B.V.
Total Pages: 473
Release: 2024-10-10
Genre: Law
ISBN: 9403538686

Series on International Taxation Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law It is well known that multinational corporations establish foreign subsidiaries in great measure to reduce their worldwide tax burden. This groundbreaking book examines the content of the substance requirement in double tax convention residence rules, transfer pricing rules, anti-abuse rules, and controlled foreign corporation rules in the context of international and EU tax law, disentangling the complex relationship between the substance requirements in these four sets of legal rules. Following a descriptive-analytic method, for each substance requirement of the four sets of legal rules, the discussion deals with the content of economic substance in complex scenarios, for example: holding companies; special purpose vehicles; loss-making subsidiaries; subsidiaries with management in more than one state; subsidiaries managed by the parent company; outsourcing; and subsidiaries ‘borrowing’ the substance of other group companies. The author introduces a new method of assessment of substance requirements, offering practical solutions for their uniform application in international and European tax law. In its thorough examination of how substance requirements work and how they are interrelated among different sets of tax rules, this book has no peers. It will be welcomed by taxation practitioners and corporate counsel in Europe and worldwide.

Corporate Taxation in the Global Economy

Corporate Taxation in the Global Economy
Author: International Monetary Fund. Fiscal Affairs Dept.
Publisher: International Monetary Fund
Total Pages: 91
Release: 2019-03-10
Genre: Business & Economics
ISBN: 149830219X

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.

International Corporate Tax Reform

International Corporate Tax Reform
Author: International Monetary
Publisher: International Monetary Fund
Total Pages: 59
Release: 2023-02-06
Genre: Business & Economics
ISBN:

To relieve the pressure on the outdated international corporate tax system, an ambitious reform was agreed at the Inclusive Framework (IF) on Base Erosion and Profit Shifting in 2021, with now 138 jurisdictions joining. It complements previous efforts to mitigate profit shifting by addressing the challenges of the digitalization of the economy through a new allocation of taxing rights to market economies (Pillar 1) and tax competition through a global minimum corporate tax (Pillar 2). This paper concludes that the agreement makes the international tax system more robust to tax spillovers, better equipped to address digitalization, and modestly raises global tax revenues.

Tax and Government in the 21st Century

Tax and Government in the 21st Century
Author: Miranda Stewart
Publisher: Cambridge University Press
Total Pages: 433
Release: 2022-09-08
Genre: Law
ISBN: 1009302442

With an accessible style and clear structure, Miranda Stewart explains how taxation finances government in the twenty-first century, exploring tax law in its historical, economic, and social context. Today, democratic tax states face an array of challenges, including the changing nature of work, the digitalisation and globalisation of the economy, and rebuilding after the fiscal crisis of the COVID-19 pandemic. Stewart demonstrates the centrality of taxation for government budgets and explains key tax principles of equity, efficiency and administration. Presenting examples from a wide range of jurisdictions and international developments, Stewart shows how tax policy and law operate in our everyday lives, ranging from family and working life to taxing multinational enterprises in the global digital economy. Employing an interdisciplinary approach to the history and future of taxation law and policy, this is a valuable resource for legal scholars, practitioners and policy makers.

Tax Evasion and Tax Havens since the Nineteenth Century

Tax Evasion and Tax Havens since the Nineteenth Century
Author: Sébastien Guex
Publisher: Springer Nature
Total Pages: 401
Release: 2023-04-18
Genre: History
ISBN: 3031181190

This collective book offers a panorama of the history of tax evasion, tax avoidance and tax havens from the nineteenth century to the present day, based on the latest research in contemporary history. It aims to show that this phenomenon is at the heart of global capitalism, partly as a response of the ruling classes to the rise of progressive taxation, but for other reasons too: notably the development of a powerful tax evasion and avoidance industry in different countries. The book argues that tax competition between states has stimulated the development of tax havens. It discusses the notion of the ‘tax haven’ and proposes a more rigorous concept - that of the ‘tax predator’. Finally, the book sheds light on the socio-political conflicts that have developed around tax evasion and the way in which states have fought against or tolerated the phenomenon.

Profit Shifting and Tax Base Erosion

Profit Shifting and Tax Base Erosion
Author: Danuše Nerudová
Publisher: Springer Nature
Total Pages: 227
Release: 2021-07-14
Genre: Business & Economics
ISBN: 3030749622

This book provides a comprehensive analysis of current techniques for profit shifting and tax base erosion in the area of corporate taxation and measurement. Firstly, it explains the relevance of the issue at hand – profit shifting and base erosion in the context of the 21st century. In turn, the book provides a comprehensive analysis of available techniques for the identification and measurement of profit shifting and base erosion, which adopt both the macro and micro perspective. It also provides examples from selected post-communist countries now in the EU, including the Czech Republic, Poland and Hungary. Concrete recommendations for economic policy round out the coverage.

Global Goliaths

Global Goliaths
Author: James R. Hines
Publisher: Brookings Institution Press
Total Pages: 585
Release: 2021-04-20
Genre: Business & Economics
ISBN: 0815738560

How multinationals contribute, or don't, to global prosperity Globalization and multinational corporations have long seemed partners in the enterprise of economic growth: globalization-led prosperity was the goal, and giant corporations spanning the globe would help achieve it. In recent years, however, the notion that all economies, both developed and developing, can prosper from globalization has been called into question by political figures and has fueled a populist backlash around the world against globalization and the corporations that made it possible. In an effort to elevate the sometimes contentious public debate over the conduct and operation of multinational corporations, this edited volume examines key questions about their role, both in their home countries and in the rest of the world where they do business. Is their multinational nature an essential driver of their profits? Do U.S. and European multinationals contribute to home country employment? Do multinational firms exploit foreign workers? How do multinationals influence foreign policy? How will the rise of the digital economy and digital trade in services affect multinationals? In addressing these and similar questions, the book also examines the role that multinational corporations play in the outcomes that policymakers care about most: economic growth, jobs, inequality, and tax fairness.

What Is Real and What Is Not in the Global FDI Network?

What Is Real and What Is Not in the Global FDI Network?
Author: Jannick Damgaard
Publisher: International Monetary Fund
Total Pages: 54
Release: 2019-12-11
Genre: Business & Economics
ISBN: 1513521527

Macro statistics on foreign direct investment (FDI) are blurred by offshore centers with enormous inward and outward investment positions. This paper uses several new data sources, both macro and micro, to estimate the global FDI network while disentangling real investment and phantom investment and allocating real investment to ultimate investor economies. We find that phantom investment into corporate shells with no substance and no real links to the local economy may account for almost 40 percent of global FDI. Ignoring phantom investment and allocating real investment to ultimate investors increases the explanatory power of standard gravity variables by around 25 percent.

Corporate Income Taxes under Pressure

Corporate Income Taxes under Pressure
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
Total Pages: 388
Release: 2021-02-26
Genre: Business & Economics
ISBN: 1513511777

The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.