scholarly journals The Analysis of the Cross-border Corporate Profit’s Taxation

2019 ◽  
Vol 11 (2) ◽  
Author(s):  
Rita Koroseczné Pavlin ◽  
Diána Koponicsné Györke
Keyword(s):  
Special Focus ◽  
Corporate Tax ◽  
Tax Base ◽  
Member States ◽  
Tax Rate ◽  
Direct Taxation ◽  
Cross Border ◽  
The Common ◽  
The Given ◽  
A Company

Ensuring the same competition conditions for the companies in EU requires tax harmonization between Member States. In this paper, we review some elements of the harmonization efforts. We will discuss the OECD guidelines on direct taxation and the transfer price regulation as a way to regulate corporate tax optimization behaviour. Based on the Effective Average Tax Rate we introduce the differences in the taxation of profits between Member States. The Common Consolidated Corporate Tax Base is one of the key elements in the harmonization of cross-border corporate profit taxation, so our study has a special focus on the proposal. The undisputed advantage of the CCCTB would be the simplification of the taxation of transactions between Member States. However, it also raises the question of how it limits the ability of each Member State to attract capital and to what extent can assign the profit tax to the given country in proportion to the operation of a company and with this how to realize that the base of the corporate tax focuses on the place of activity.      

scholarly journals TAX HARMONIZATION ASEAN MELALUI ASEAN TAX FORUM -PEMBELAJARAN DARI PROSES TAX HARMONIZATION UNI EROPA-

2015 ◽  
Vol 15 (1) ◽  
pp. 33
Author(s):  
Suska Suska ◽  
Yuventus Effendi
Keyword(s):  
Corporate Tax ◽  
Double Taxation ◽  
Tax Base ◽  
Member States ◽  
Tax Rate ◽  
Tax Harmonization ◽  
Harmonization Process ◽  
The Common ◽  
Asean Countries ◽  
Asean Economic Community

ASEAN Tax Forum was established in the ASEAN Minister of Finance meeting in Bali April 2011. The forum consists of tax authority among ASEAN countries intended for exchange of information on the tax regime and instruments among Member States as well as to work on the issues of avoidance of double taxation and addressing withholding tax to further support the building of a competitive ASEAN Economic Community. The tax harmonization process among member states of ASEAN needs several stages to be taken. Tax Treaty as the step to eliminate the double taxation still not implemented by all ASEAN members. Tax rate particularly corporate tax rate is varying among countries. Learning the lesson from European Union, the direction of tax harmonization is to establish the common tax base while tax rate still differentiate among member states.

scholarly journals The international Challenges and Finnish Corporate Taxation

2014 ◽  
Vol 2014 (2) ◽  
pp. 132-148
Author(s):  
Juha Lindgren
Keyword(s):  
Corporate Taxation ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Cross Border ◽  
Exchange Of Information ◽  
The Cross ◽  
National Tax

Abstract One of the main trends in Finnish corporate taxation during the last ten years has been the lowering of the corporate tax rate. The decision to lower the corporate tax rate to 20% from the beginning of 2014 also changed the approach in reforming the corporate taxation as it was decided to stay on the grounds of a broad tax base and not to make loopholes in it with targeted exceptions. The Finnish corporate taxation contains also some provisions that act as incentives for investment and the establishment of companies. However, the focus has been lately on the rules with purpose to protect the national tax base. Therefore, article handles both the specific anti avoidance rules and the application of the general anti avoidance rule on the cross-border transactions. Some particular challenges and the exchange of information are also taken into account before the conclusion with some ideas and aspects on future reforms.

scholarly journals Tax sharing under the Common Consolidated Corporate Tax Base: Measurement of the profit generating factors in the agriculture sector

2016 ◽  
Vol 62 (No. 8) ◽  
pp. 363-377 ◽  
Author(s):  
Nerudova Danuse ◽  
Krchniva Katerina
Keyword(s):  
Special Focus ◽  
Corporate Tax ◽  
Tax Base ◽  
The Czech Republic ◽  
Agriculture Sector ◽  
Base Measurement ◽  
The Common ◽  
The Difference ◽  
Tax Sharing ◽  
The Individual

The allocation formula for the distribution of the Common Consolidated Corporate Tax Base (CCCTB) should be based on three macroeconomics factors which are considered to have the largest impact on profitability. The paper researches the ability of the allocation formula factors to explain variability in profit/loss generation of single enterprises from the perspective of the Czech Republic with the special focus on the explanation power of the allocation formula on profit/loss generation of companies operating in the agriculture sector (NACE A). The analysis is based on the comparison of the coefficients of determination as an indicator of the explained variability of the proposed simple as well as the multiple regression models. The paper concludes that proportion of explained profitability by the formula factors as are defined by the Draft Directive on a Common Consolidated Corporate Tax Base can differ by more than 30% with regard to the sector of economic activity classified by the NACE, whereas in the individual subsectors of the agriculture the difference may amount to 40%.

scholarly journals Abuses and Penalties of a Corporate Tax Inversion

2019 ◽  
Vol 7 (1) ◽  
pp. 5
Author(s):  
James Yang ◽  
Leonard Lauricella ◽  
Frank Aquilino
Keyword(s):  
Multinational Corporations ◽  
International Taxation ◽  
Internal Revenue Service ◽  
Tax Law ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Tax Savings ◽  
Treasury Department ◽  
The U.S

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 “corporate tax inversion”. This paper discusses the abuses and penalties of this phenomenon. It is rooted in some deficiencies in the U.S. tax law. This paper points out that the U.S. has the highest corporate tax rate in the world. It imposes tax on worldwide income. It permits deferral of tax on foreign-sourced income until dividends are repatriated back to the U.S. As a result, it creates tax loopholes. This paper reveals six actual cases of corporate tax inversion. This practice has triggered the Congress to enact §7874, the Internal Revenue Service (IRS) to issue Notices IR 2014-52 and IR 2015-79, and the U.S. Treasury Department to promulgate TD 9761. This paper investigates some details of these penalties. This paper further demonstrates an example in determining the amount of tax savings by engaging in a corporate tax inversion. It also offers many strategies.

scholarly journals An Estimable Model of Income Redistribution in a Federation: Musgrave Meets Oates

2019 ◽  
Vol 11 (1) ◽  
pp. 406-434 ◽  
Author(s):  
Kevin Milligan ◽  
Michael Smart
Keyword(s):  
Tax Avoidance ◽  
Tax Base ◽  
Tax Rate ◽  
Personal Taxes ◽  
Cross Border ◽  
State Tax ◽  
Decentralization Reform ◽  
National Tax ◽  
Optimal Taxes ◽  
Personal Taxation

We develop a theory of cross-border income shifting in response to subnational personal taxation in a federation and examine its implications for the excess burden of personal taxes. We show how a properly chosen federal tax rate can offset the fiscal externality between states and facilitate decentralization, even in a heterogeneous federation where unitary taxation is suboptimal. Optimal taxes depend on the elasticities of national tax avoidance and of cross-state tax base shifting. We estimate these elasticities around a tax decentralization reform in Canada, finding both to be empirically relevant. We discuss the implications for optimal federalism. (JEL D31, H21, H23, H24, H26, H71, H77)

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