International tax arbitrage, tax evasion and interest parity conditions

2001 ◽  
Vol 55 (4) ◽  
pp. 413-427 ◽  
Author(s):  
Frank Strobel
Keyword(s):  
Tax Evasion ◽  
Tax Arbitrage ◽  
Interest Parity ◽  
International Tax

How Countries Should Share Tax Information

2019 ◽  
pp. 303-322
Author(s):  
Arthur J. Cockfield
Keyword(s):  
Human Rights ◽  
Transaction Costs ◽  
Tax Evasion ◽  
Academic Support ◽  
Tax Planning ◽  
High Quality ◽  
Financial Flows ◽  
Optimal Outcomes ◽  
Illicit Financial Flows ◽  
International Tax

This chapter looks at exchange of information (EOI) policies, proposing several ways to make EOI policies fairer and more efficient, so as to maximize their potential to reduce illicit financial flows and curb abusive tax practices that undermine human rights. While there appears increasing policy and academic support for EOI initiatives that promote global financial transparency, the current international tax regime, with its high transaction costs for taxpayers and tax authorities, does not seem particularly amenable to producing optimal outcomes. The chapter then emphasizes how, to promote enforceability, the ideal EOI system delivers high-quality tax information while providing needed legal protections for taxpayer privacy. The exchange and usage of high-quality tax information would reduce transaction costs for tax authorities as they could more readily identify taxpayers engaged in offshore tax evasion and aggressive international tax planning.

Supply Chain Strategies and International Tax Arbitrage

2016 ◽  
Vol 26 (2) ◽  
pp. 231-251 ◽  
Author(s):  
Masha Shunko ◽  
Hung T. Do ◽  
Andy A. Tsay
Keyword(s):  
Supply Chain ◽  
Tax Arbitrage ◽  
International Tax

scholarly journals International development of the concept of taxation of a permanent representation of a foreign company as an “independent taxpayer” and the experience of its application in the Russian Federation

2021 ◽  
pp. 16-25
Author(s):  
Pavel Igorevich Yakovlev
Keyword(s):  
International Development ◽  
Russian Federation ◽  
Tax Evasion ◽  
Foreign Company ◽  
Double Taxation ◽  
Foreign Companies ◽  
Tax Legislation ◽  
The Russian Federation ◽  
International Tax ◽  
Model Agreement

The subject of this research is the development of the concept of taxation of permanent representations of foreign companies on the international level and its application in the Russian Federation. The object of this research is the permanent representations of foreign companies. The author examines such aspects of the topic, as the use of agreements on avoidance of double taxation, countering the tax base erosion, and the international approach towards taxation of the permanent representation of a foreign company as an independent participant of the market relations. Analysis is conducted on the need for amending the Model Agreement of the Russian Federation of 02.24.2010 No. 84 “On conclusion of intergovernmental agreements on avoidance of double taxation and on prevention of tax evasion on the income and property”. The author traces the transformation of attitude of international tax organizations towards the concept of permanent representation and substantiation of their choice of the concept of taxation of a permanent representation as an independent taxpayer. The scientific novelty is proven by the facts of application of this concept of taxation of permanent representation in the national legislation of multiple countries, international agreements on avoidance of double taxation, Russian national tax legislation and arbitration practice. The main conclusion consists in the response to the selected by the international tax organizations concept of taxation of a permanent representation. The author offers to amend the Model Agreement of the Russian Federation of 02.24.2010 No. 84 “On conclusion of intergovernmental agreements on avoidance of double taxation and on prevention of tax evasion on the income and property”.

Power in International Tax Politics

2020 ◽  
pp. 25-48
Author(s):  
Lukas Hakelberg
Keyword(s):  
Tax Evasion ◽  
Tax Policy ◽  
Domestic Politics ◽  
Good Governance ◽  
The United States ◽  
The European Union ◽  
Administrative Authority ◽  
The Us ◽  
Regulatory Capacity ◽  
International Tax

This chapter develops a theory of power in international tax politics. This theory identifies market size and regulatory capacity as the decisive resources enabling governments to issue credible threats and inducements with a view toward making other governments do what they would not otherwise do. A lack of regulatory capacity explains why the European Union has not wielded the same power in negotiations over global tax policy as the United States despite the EU's similarly sized internal market. In fact, taxation remains an exclusive member state competence. Therefore, the European Commission has no administrative authority to impose penalties on third states or foreign firms not complying with tax good governance standards applicable within the union. At the same time, the principle of nondiscrimination enshrined in EU law prevents individual EU countries from passing sanctions against other member states abetting tax evasion and avoidance. Because of the lack of regulatory centralization in the EU, the US can act as a hegemon in international tax politics. Accordingly, US preferences determined by domestic politics decisively shape the content of global tax policy. The preferences of other governments merely affect the US administration's enforcement strategy.

Change and Stability in Global Tax Policy

2020 ◽  
pp. 1-24
Author(s):  
Lukas Hakelberg
Keyword(s):  
United States ◽  
Tax Evasion ◽  
Tax Policy ◽  
Market Access ◽  
The United States ◽  
Great Power ◽  
Fundamental Change ◽  
Tax Havens ◽  
International Tax ◽  
International Tax Policy

This chapter takes a look at the ability of a great power like the United States to unilaterally effect fundamental change in international tax policy through coercion. It first shows that the structural constraints precluding a common interest in countermeasures to tax evasion were still in place when the US Congress passed the Foreign Account Tax Compliance Act (FATCA). Second, the chapter reveals that there was no need for normative change, because regulative norms have never consistently prevented the United States from interfering with the legal systems of tax havens. From there, the chapter considers when a great power like the United States can effect fundamental change in international tax policy and the domestic tax policies of less powerful countries through coercion. It argues that a government reaches great power status if it controls an internal market large enough to reduce its dependence on international trade and investment relative to the government's negotiating partners and uses its regulatory capacity to effectively restrict market access for foreign firms or investors.

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