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Pareto-Improving Minimum Corporate Taxation

Pareto-Improving Minimum Corporate Taxation
Author: Mr. Shafik Hebous
Publisher: International Monetary Fund
Total Pages: 23
Release: 2021-10-22
Genre: Business & Economics
ISBN: 155775618X

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The recent international agreement on a minimum effective corporate tax rate marks a profound change in global tax arrangements. The appropriate level of that minimum, however, has been, and remains, extremely contentious. This paper explores the strategic responses to a minimum tax, which—the policy objective being to change the rules of tax competition game--—are critical for assessing the design and welfare impact of, and prospects for, this fundamental policy innovation. Analysis and calibration plausibly suggest sizable scope for minima that are Pareto-improving, benefiting low as well as high tax countries, over the uncoordinated equilibrium.


Federal Corporate Taxation

Federal Corporate Taxation
Author: Howard E. Abrams
Publisher:
Total Pages: 312
Release: 1987
Genre: Business & Economics
ISBN:

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The Fourth Edition of Abrams & Doernberg's Federal Corporate Taxation includes: * New debt/equity limitations ("non-qualified preferred stock") in corporate formations & reorganizations * Anti-abuse redemption provisions covering stock options & sales between related corporations * The anti-Morris Trust changes to tax-free spin-offs * Liberalization of Subchapter S shareholder restrictions & changes to timing of Subchapter S distributions ###1-56662-799-0


Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax

Efficient Economic Rent Taxation Under a Global Minimum Corporate Tax
Author: Mr. Shafik Hebous
Publisher: International Monetary Fund
Total Pages: 41
Release: 2024-03-15
Genre: Business & Economics
ISBN:

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The international agreement on a corporate minimum tax is a milestone in global corporate tax arrangements. The minimum tax disturbs the equivalence between otherwise equivalent forms of efficient economic rent taxation: cash-flow tax and allowance for corporate equity. The marginal effective tax rate initially declines as the statutory tax rate rises, reaching zero where the minimum tax is inapplicable, and increases thereafter. This kink occurs at a lower statutory rate under cash-flow taxation. We relax the assumption of full loss offset; provide a routine for computing effective rates under different designs; and discuss policy implications of the minimum tax.


Fiscal Policy in a Turbulent Era

Fiscal Policy in a Turbulent Era
Author: Enrique Alberola
Publisher: Edward Elgar Publishing
Total Pages: 253
Release: 2024-02-12
Genre: Business & Economics
ISBN: 1035300567

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Recognising the regained importance of fiscal policy over the last two decades, this timely book provides much-needed insight into the changing practice of fiscal policy and how it is adapting to the unpredictable nature of the 21st century. Expert academic and practitioner contributors consider the resources which underpin current fiscal policy, assessing its overall effectiveness before outlining the changing priorities –ageing, inequality, climate change- and the financial tools available, and considering the future of fiscal policy in uncertain times.


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:

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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.


The 'Pillar Two' Global Minimum Tax

The 'Pillar Two' Global Minimum Tax
Author: Werner Haslehner
Publisher: Edward Elgar Publishing
Total Pages: 353
Release: 2024-08-06
Genre: Law
ISBN: 1035308746

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Bringing together leading experts in the field of tax law, this book comprehensively analyses the new global minimum taxation regime for multinational companies. Not only does it consider this unprecedented diplomatic achievement in its historic, economic and political context, but the book also explores the intricate technical detail of the GloBE model rules.


Deciphering the GloBE in a Low-Tax Jurisdiction

Deciphering the GloBE in a Low-Tax Jurisdiction
Author: Mr. Shafik Hebous
Publisher: International Monetary Fund
Total Pages: 26
Release: 2024-03-22
Genre: Business & Economics
ISBN:

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Pillar Two rules of the Inclusive Framework agreement on a minimum corporate tax (known as ‘Global Anti-Base Erosion Rules’, for short GloBE) have important implications for the design of the corporate income tax. This chapter discusses these implications particularly from the perspective of low-tax jurisdictions. It argues that it is not possible to design a system that always guarantees generating exactly the bare minimum tax intended by the rules and motivates that this should not be the policy objective anyway. Importantly, if no profit tax already exists, countries need to consider whether to adopt one, and if yes, in what form. There is a case for introducing a general profit tax beyond the GloBE rules, together with a qualifying GloBE domestic minimum top-up tax as a backstop. The familiar alternatives of efficient economic rent tax designs, however, are no longer equivalent under the GloBE. In practice, given the specifics of the rules, an efficient rent tax on in-scope multinationals cannot be combined with a statutory tax rate below a certain cutoff, because the minimum tax becomes always binding. Under the GloBE, immediate expensing particularly maintains the time-value of fully deducting the cost of investment, without impacting the GloBE effective tax rate.


Taxing Profit in a Global Economy

Taxing Profit in a Global Economy
Author: Michael P. Devereux
Publisher: Oxford University Press
Total Pages: 401
Release: 2020-09-29
Genre: Business & Economics
ISBN: 0198808062

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The international tax system is in dire need of reform. It allows multinational companies to shift profits to low tax jurisdictions and thus reduce their global effective tax rates. A major international project, launched in 2013, aimed to fix the system, but failed to seriously analyse the fundamental aims and rationales for the taxation of multinationals' profit, and in particular where profit should be taxed. As this project nears its completion, it is becomingincreasingly clear that the fundamental structural weaknesses in the system will remain. This book, produced by a group of economists and lawyers, adopts a different approach and starts from first principles in order to generate an international tax system fit for the 21st century. This approach examines fundamental issues of principle and practice in the taxation of business profit and the allocation of taxing rights over such profit amongst countries, paying attention to the interests and circumstances of advanced and developing countries. Once this conceptual framework is developed, the book evaluates the existing system and potential reform options against it. A number of reform options are considered, ranging from those requiring marginal change to radically different systems. Some options have been discussed widely. Others, particularly Residual Profit Split systems and a Destination Based Cash-Flow Tax, are more innovative and have been developed at some length and in depth for the first time in this book. Their common feature is that they assign taxing rights partly/fully to the location of relatively immobile factors: shareholders or consumers.


International Tax Spillovers and Tangible Investment, with Implications for the Global Minimum Tax

International Tax Spillovers and Tangible Investment, with Implications for the Global Minimum Tax
Author: Mr. Michael Keen
Publisher: International Monetary Fund
Total Pages: 80
Release: 2023-08-04
Genre: Business & Economics
ISBN:

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This paper articulates and, using newly-assembled data, explores how international taxation affects aggregate tangible cross-border investment. Spillovers from statutory tax rates abroad seem: As sizable as effects from the host’s rate; larger than previous consensus values (attributed to a systematic bias from FDI data); and consistent with ‘implicit’ profit shifting through real investment (rather than ‘paper’ profit shifting). Contrary to much policy discussion, the results also imply that: Host countries’ marginal effective tax rates have at best a weak effect on real investment; those elsewhere have none; and, applied to the prospective global minimum tax, inward tangible investment in most sample countries will increase.