Why Corporate Taxation Should Mean Source Taxation A Response To The Oecds Actions Against Base Erosion And Profit Shifting PDF Download
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Author | : L.U. Cavelti |
Publisher | : |
Total Pages | : |
Release | : 2017 |
Genre | : |
ISBN | : |
Download Why Corporate Taxation Should Mean Source Taxation : a Response to the OECD's Actions Against Base Erosion and Profit Shifting Book in PDF, ePub and Kindle
It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the "country of source". This article questions separate taxation based on this distinction between the country of residence and the country of source. It argues for a departure from the traditional international allocation of the right to tax corporate income and suggests that a corporate entity should instead pay income tax exclusively to the countries in which it has relevant business activities. In other words, this article advocates a "source-based corporate income tax", meaning the global allocation of corporate income based on the source of income. Moreover, in examining the question of where business activities of multinational corporations effectively take place, this article describes criteria for determining source countries. Furthermore, it offers a method for formulary apportionment of corporate income between those countries in which a given multinational corporation generates income. The article argues that source taxation of corporate income would be coherent with the economic nature of corporate income taxation. Source taxation of corporate income would also make the arbitrary concept of corporate residence irrelevant, and it would allow the outdated legal concept of permanent establishment to be abolished. This article takes an interdisciplinary approach to argue from both legal and economic perspectives. It adds to the body of literature that discusses how countries should tax corporate entities doing business across national borders. It also contributes to the ongoing debate about the OECD's recent controversial efforts to prevent corporations shifting profits between countries to minimize their exposure to national tax systems (base erosion and profit sharing, or BEPS).
Author | : Luzius U. Cavelti |
Publisher | : |
Total Pages | : 0 |
Release | : 2023 |
Genre | : |
ISBN | : |
Download Why Corporate Taxation Should Mean Source Taxation Book in PDF, ePub and Kindle
It is widespread practice around the world that corporate entities pay taxes to the country where they are formally registered and to the country in whose territory they generate income. While the former is generally known as the "country of residence" the latter is usually referred to as the "country of source". This article questions separate taxation based on this distinction between the country of residence and the country of source. It argues for a departure from the traditional international allocation of the right to tax corporate income and suggests that a corporate entity should instead pay income tax exclusively to the countries in which it has relevant business activities. In other words, this article advocates a "source-based corporate income tax", meaning the global allocation of corporate income based on the source of income. Moreover, in examining the question of where business activities of multinational corporations effectively take place, this article describes criteria for determining source countries. Furthermore, it offers a method for formulary apportionment of corporate income between those countries in which a given multinational corporation generates income. The article argues that source taxation of corporate income would be coherent with the economic nature of corporate income taxation. Source taxation of corporate income would also make the arbitrary concept of corporate residence irrelevant, and it would allow the outdated legal concept of permanent establishment to be abolished. This article takes an interdisciplinary approach to argue from both legal and economic perspectives. It adds to the body of literature that discusses how countries should tax corporate entities doing business across national borders. It also contributes to the ongoing debate about the OECD's recent controversial efforts to prevent corporations shifting profits between countries to minimize their exposure to national tax systems (base erosion and profit sharing, or BEPS).Full-text Paper.
Author | : Luzius U. Cavelti |
Publisher | : |
Total Pages | : |
Release | : 2016 |
Genre | : |
ISBN | : |
Download Why Corporate Taxation Means Source Taxation Book in PDF, ePub and Kindle
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 91 |
Release | : 2013-02-12 |
Genre | : |
ISBN | : 9264192743 |
Download Addressing Base Erosion and Profit Shifting Book in PDF, ePub and Kindle
This report presents studies and data available regarding the existence and magnitude of base erosion and profit shifting (BEPS), and contains an overview of global developments that have an impact on corporate tax matters.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 44 |
Release | : 2013-07-19 |
Genre | : |
ISBN | : 9264202714 |
Download Action Plan on Base Erosion and Profit Shifting Book in PDF, ePub and Kindle
This action plan, created in response to a request by the G20, identifies a set of domestic and international actions to address the problems of base erosion and profit sharing.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 82 |
Release | : 1998-05-19 |
Genre | : |
ISBN | : 9264162941 |
Download Harmful Tax Competition An Emerging Global Issue Book in PDF, ePub and Kindle
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 651 |
Release | : 2021-04-29 |
Genre | : |
ISBN | : 9264438181 |
Download Taxing Wages 2021 Book in PDF, ePub and Kindle
This annual publication provides details of taxes paid on wages in OECD countries. It covers personal income taxes and social security contributions paid by employees, social security contributions and payroll taxes paid by employers, and cash benefits received by workers. Taxing Wages 2021 includes a special feature entitled: “Impact of COVID-19 on the Tax Wedge in OECD Countries”.
Author | : Oecd |
Publisher | : Org. for Economic Cooperation & Development |
Total Pages | : 100 |
Release | : 2015-10-20 |
Genre | : |
ISBN | : 9789264241374 |
Download OECD/G20 Base Erosion and Profit Shifting Project Mandatory Disclosure Rules, Action 12 - 2015 Final Report Book in PDF, ePub and Kindle
Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 12.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 355 |
Release | : 2021-09-15 |
Genre | : |
ISBN | : 9264424083 |
Download Tax Administration 2021 Comparative Information on OECD and other Advanced and Emerging Economies Book in PDF, ePub and Kindle
This report is the ninth edition of the OECD's Tax Administration Series. It provides internationally comparative data on aspects of tax systems and their administration in 59 advanced and emerging economies.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 24 |
Release | : 2016-08-26 |
Genre | : |
ISBN | : 9264263438 |
Download OECD/G20 Base Erosion and Profit Shifting Project BEPS Project Explanatory Statement 2015 Final Reports Book in PDF, ePub and Kindle
Addressing base erosion and profit shifting is a key priority of governments around the globe. This Explanatory Statement offers an overview of the BEPS Project and outcomes.