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Business and Economics > Corporate Taxation

You are looking at 1 - 10 of 14 items for :

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  • Multinational Firms; International Business x
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Cover IMF Working Papers
Deciphering the GloBE in a Low-Tax Jurisdiction
Shafik Hebous
,
Cory Hillier
, and
Andualem Mengistu
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.
Keywords:
Investment; Minimum Tax; Tax Competition; Rent Taxation; Cash-Flow Tax; International Taxation; scope multinational; profit tax; top-up tax; tax design; Corporate income tax; Allowance for corporate equity; Corporate taxes; Tax allowances; Global
Cover IMF Working Papers
Efficient Economic Rent Taxation under a Global Minimum Corporate Tax
Shafik Hebous
and
Andualem Mengistu
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.
Keywords:
Investment; Minimum Taxation; Corporate Tax Reform; International Taxation; Rent Tax; ACE; Effective Tax Rate; policy implication; top-up tax; minimum tax; depreciation rate; Cash-flow tax; Allowance for corporate equity; Marginal effective tax rate; Average effective tax rate; Corporate income tax; Global
Cover IMF Working Papers
Home or Away? Profit Shifting with Territorial Taxation
Dominika Langenmayr
and
Ms. Li Liu
In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that the profitability of UK subsidiaries in low-tax countries increased after the reform compared to subsidiaries of non-UK multinationals in the same countries by an average of 2 percentage points. This increase in profit shifting also leads to increases in measured productivity of the foreign affiliates of UK multinationals of between 5 and 9 percent.
Keywords:
profit shifting; territorial tax system; multinational firms; shifted profit; UK multinational; UK subsidiary; difference-in-differences research design; Total factor productivity; Transnational corporations; Corporate income tax; Income; Wages; Global
Cover IMF Working Papers
Pareto-Improving Minimum Corporate Taxation
Mr. Shafik Hebous
and
Mr. Michael Keen
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.
Keywords:
Tax Competition; Minimum Taxation; Corporate Tax Reform; International Taxation; competition game; policy objective; corporate tax reform; best response; country benefit; residence country; Corporate income tax; Competition; Tax avoidance; Global
Cover Departmental Papers
Tax Avoidance in Sub-Saharan Africa’s Mining Sector
Ms. Giorgia Albertin
,
Boriana Yontcheva
,
Dan Devlin
,
Hilary Devine
,
Mr. Marc Gerard
,
Sebastian Beer
,
Irena Jankulov Suljagic
, and
Mr. Vimal V Thakoor
This paper aims to contribute to the international policy debate around profit shifting, tax avoidance and SSA’s revenue mobilization efforts in three ways. First, it examines the importance of mining, the role of multinational enterprises (MNEs), and mining revenue outcomes in SSA. Second, it assesses the magnitude of profit shifting in mining drawing on new macro level research, supplemented by case studies to illustrate the lived experience of tax avoidance in SSA mining. Third, the paper identifies tax policy reforms that could boost revenue mobilization in SSA.
Keywords:
International Taxation, Corporate Income Taxation, Multinational Enterprises, Profit Shifting, Mining, Developing Countries, Africa, Revenue Mobilization, Tax Incentives, Tax Avoidance.; mining revenue outcome; mining MNE profits; SSA economy; natural resource taxation; MNE tax avoidance; revenue loss; SSA resource-intensive country; profit shifting; Mining sector; Corporate income tax; Corporate taxes; Withholding tax; Tax incentives; Africa; Sub-Saharan Africa; Global
Cover IMF Working Papers
Global Firms, National Corporate Taxes: An Evolution of Incompatibility
Mr. Shafik Hebous
How did the rise of multinational enterprises (MNEs) put pressure on the prevailing international corporate tax framework? MNEs, and firms with market power, are not new phenomena, nor is the corporate income tax, which dates to the early 20th century. This prompts the question, what is distinctly new (about multinational enterprises)—if anything—that has triggered unprecedented recent concerns about vulnerabilities in international tax arrangements and the taxation of MNEs? This paper presents a set of empirical observations and a synthesis of strands of the literature to answer this question. A key message is that MNEs of the 21st century operate differently from prior periods and have evolved to become global firms—with important tax ramifications. The fragility of international tax arrangements was present at the outset of designing international tax rules, but the challenges have drastically intensified with the global integration of business, the increased trade in hard-to-price services and intangibles, and the rapid growth of the digital economy.
Keywords:
WP; company; multinational enterprise; conduit company; holding company; business organization; Multinational enterprises; global firm; tax avoidance; international tax; management company; credit card company; financing company; Corporate income tax; Foreign direct investment; Double taxation; Trade in services; Personal income; Global
Cover IMF Working Papers
An Assessment of Global Formula Apportionment
Ruud A. de Mooij
,
Ms. Li Liu
, and
Dinar Prihardini
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative to the current international tax regime that is based on separate accounting. It highlights major advantages, such as the elimination of profit shifting within multinational groups; and it discusses new distortions and the impact on tax competition. The analysis exploits different datasets to assess the direct revenue implications for individual countries under alternative formulas. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in investment hubs (i.e. countries with a disproportionate ratio of foreign direct investment to GDP), while several large advanced countries are likely to gain. Developing countries gain most likely if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination.
Keywords:
WP; parent company; taxable income; company group; company transaction; enterprise tax.; non-loss-making company; International corporate taxation; Multinationals; Formula apportionment; enterprise tax; tax competition; data from ORBIS; tax enforcement; revenue effect; Corporate income tax; Personal income; Employment; Global; Europe
Cover IMF Working Papers
The Cost and Benefits of Tax Treaties with Investment Hubs: Findings from Sub-Saharan Africa
Sebastian Beer
and
Jan Loeprick
This paper investigates the costs and benefits of concluding double tax treaties with investment hubs. Based on a sample of 41 African economies from 1985–2015, the results suggest that signing treaties with investment hubs is not associated with additional investments; yet, these treaties tend to come with nonnegligible revenue losses. Building on a theoretical model, the paper investigates the role of treaty shopping in driving nominal investment flows and provides indirect evidence for its importance in the sample
Keywords:
WP; tax revenue; income tax; Tax Treaty Policy; Double Tax Treaties; Domestic Resource Mobilization; Mauritius; Sub-Saharan Africa; CIT revenue; cost of capital; withholding tax tax rate; tax cost; revenue loss; Investment hubs; cost parameter; repatriation impact FDI stock; FDI equation; effects of DTTS; revenue efficiency; tax revenue equation; Corporate income tax; Foreign direct investment; Double taxation; Withholding tax; Global; Africa
Cover IMF Working Papers
Foreign Direct Investment in New Member State of the EU and Western Balkans: Taking Stock and Assessing Prospects
La-Bhus Fah Jirasavetakul
and
Jesmin Rahman
FDI has played a strong role in the export-led growth of eastern European countries that are now members of the European Union (EU). Largely sourced from advanced Europe, FDI inflows were motivated by the intention to pursue new markets and cost efficiency. Over time, foreign investment has restructured the exports sector in these countries in favor of products that are considered more technology-intensive. As these countries face skills shortage and rising wages, what is needed for FDI to continue playing a strong role? Can the Western Balkan countries, who are not yet EU members and have in recent years stepped up financial incentives and policy initiatives to court investors, emulate the experience? This paper takes stock of the FDI experience of both these groups and tries to estimate their potential gains from additional policy efforts.
Keywords:
WP; FDI inflow; WB country; host country; EU accession; EU country; FDI flow; FDI stock; Foreign direct investment; determinants of FDI; catching-up process; EU New Member States; Western Balkans; gravity model; panel analysis; inflow regression; Corporate income tax; Tax holidays; Manufacturing; Stocks; Global; Europe
Cover IMF Working Papers
International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots
Sebastian Beer
,
Ruud A. de Mooij
, and
Ms. Li Liu
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
Keywords:
WP; tax rate; passive income; dependent variable; Corporate taxation; Multinationals; Profit shifting; International tax avoidance; Meta analysis; host-country tax; company debt; residence country; firm FE; consensus estimate; debt shifting; profit reallocation; elasticity estimate; company transaction; single tax; Corporate income tax; Tax avoidance; Corporate taxes; Personal income; Global