A Destination-Based Allowance for Corporate Equity

A Destination-Based Allowance for Corporate Equity
Author: Shafik Hebous
Publisher: International Monetary Fund
Total Pages: 26
Release: 2018-11-08
Genre: Business & Economics
ISBN: 148438413X

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
Total Pages: 26
Release: 2018-11-08
Genre: Business & Economics
ISBN: 1484381904

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
Total Pages: 78
Release: 2016-12-10
Genre: Business & Economics
ISBN: 1498345204

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
Total Pages: 46
Release: 2021-09-24
Genre: Business & Economics
ISBN: 1513596624

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
Total Pages: 68
Release: 2004
Genre: Business & Economics
ISBN:

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.

OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax

OECD Tax Policy Studies Fundamental Reform of Corporate Income Tax
Author: OECD
Publisher: OECD Publishing
Total Pages: 174
Release: 2007-11-13
Genre:
ISBN: 9264038124

Presents the recent trends in the taxation of corporate income in OECD countries, discusses the main drivers of corporate income tax reform and evaluates the gains of fundamental corporate tax reform.

No Business Taxation Without Model Representation

No Business Taxation Without Model Representation
Author: Benjamin Carton
Publisher: International Monetary Fund
Total Pages: 61
Release: 2017-11-17
Genre: Business & Economics
ISBN: 1484326016

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
Total Pages: 91
Release: 2019-03-10
Genre: Business & Economics
ISBN: 1498302254

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
Total Pages: 529
Release: 2023-09-21
Genre: Law
ISBN: 1509963286

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.

Pouring Oil on Fire: Interest Deductibility and Corporate Debt

Pouring Oil on Fire: Interest Deductibility and Corporate Debt
Author: Pietro Dallari
Publisher: International Monetary Fund
Total Pages: 42
Release: 2018-12-07
Genre: Business & Economics
ISBN: 1484389107

This paper investigates the role of tax incentives towards debt finance in the buildup of leverage in the nonfinancial corporate (NFC) sector, using a large firm-level dataset. We find that so-called debt bias is a significant driver of leverage, for both small and medium-sized enterprises and larger firms, with its effect accounting for about a quarter of leverage. The strength of this effect differs with firm size, the availability of collateral, income and income volatility, cash flow, and capital intensity. We conclude that leveling the playing field between debt and equity finance through tax policy reform would decrease NFC leverage, reducing economic risks posited by leverage.