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Business and Economics > Corporate Taxation

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  • Efficiency; Optimal Taxation x
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Cover Tax Law Technical Note
Legislating for Fair and Effective Tax Collection
Irving Aw
,
Brendan Crowley
,
Cory Hillier
,
Rose A Nyongesa
,
Lydia E Sofrona
, and
Christophe J Waerzeggers
Fair and effective tax collection is critical to the success of any tax system in raising revenue and should be properly legislated. Voluntary payment of taxes by taxpayers is always preferred and should be encouraged and supported by the tax procedure legal framework. However, the law should also provide for protective measures to prevent taxpayers from frustrating tax collection efforts by taking either themselves or their assets out of the tax administration’s reach. As a last resort, the tax administration should be able to compel the recovery of outstanding tax debts from taxpayers or certain third parties through different legislative measures. Such powers should however be complemented by adequate safeguards for taxpayers. This note focuses on the key issues that should be taken into consideration in designing tax law provisions to support fair and effective tax collection.
Keywords:
Tax Collection; Legislation; Protective Measures; Compelled Recovery; Tax Liens; Installment Arrangements; Crisis Events; clearance mechanism; penalties regime; tax procedure; tax law provision; clearance certificate; tax rulings regime; IT system; Tax administration core functions; Tax arrears management; Tax law; Collateral
Cover IMF Working Papers
Citizens Perceptions of Tax Authorities and Tax Efficiency
Telma Yamou
,
Alun H. Thomas
, and
Kaihao Cai
This paper examines the relationship between citizens’ perceptions of tax authorities and the governments’ efficiency in collecting VAT and CIT revenues in Africa. Drawing on data from 32 countries over 2014-2019, we find a negative and significant association between negative perceptions of trust in authorities (the tax department) from the Afrobarometer survey and tax efficiency for these revenue categories. A 1 percent increase in the share of citizens’ perception of little or no trust in the tax department leads to a 0.22 percent decrease in VAT tax efficiency, controlling for macroeconomic indicators. The magnitude of the effect is significantly greater in fragile compared to non-fragile states. For corporate income tax productivity focusing on tax payments of corporates we find a significant effect only in fragile states. Perceptions about corruption in tax authorities have a similar effect on VAT and CIT tax efficiency since perceptions about trust and corruption capture the tendency to misappropriate revenues but we are unable to distinguish the two effects except for fragile states. Our findings suggest that in the face of fragility, policies aimed at improving fiscal capacity should place a high importance on ensuring that citizens believe resources will be used properly, an aspect of tax policy not typically prioritized.
Keywords:
Trust in authorities; fragility; tax efficiency; Africa; tax authorities; tax department; payments of corporate; tax payment; CIT efficiency; Corporate income tax; Corruption; Value-added tax
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 Technical Notes and Manuals
Corporate Income Tax Gap Estimation by using Bottom-Up Techniques in Selected Countries: Revenue Administration Gap Analysis Program
Patricio A Barra
,
Mr. Eric Hutton
, and
Polina Prokof'yeva
This technical note describes bottom-up CIT gap estimation techniques applied by revenue administrations in the following highly experienced countries in this approach: Australia, Brazil, Canada, Denmark, Sweden, the United Kingdom, and the United States. The main topics included in the descriptions are techniques applied, CIT gap results, advantages and disadvantages of different available options, and future developments and recommendations for any revenue administration interested in starting bottom-up CIT gap estimation programs having no prior experience.
Keywords:
Tax Administration; Tax Compliance; Corporate Income Tax; Tax Gap; Tax Evasion; Random Audit Program; Risk-Based Audits; bottom-up technique; CIT gap; gap definition; Ra-GAP team; members of the Revenue Administration Gap Analysis Program; Auditing; Revenue Administration Gap Analysis Program (RA-GAP); Small and medium enterprises
Cover IMF Working Papers
International Tax Spillovers and Tangible Investment, with Implications for the Global Minimum Tax
Mr. Michael Keen
,
Ms. Li Liu
, and
Hayley Pallan
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.
Keywords:
Corporate Taxation; International Tax; Multinational Investment; Foreign Direct Investment; host country; Affiliate investment; FDI data; investment impact; corporate tax tax rate; cross-border investment; Corporate income tax; Marginal effective tax rate; International tax issues; Capital account; Global
Cover IMF How To Notes
How to Design a Presumptive Income Tax for Micro and Small Enterprises
Jean-François Wen
Turnover taxes are prevalent in developing countries as a simple form of presumptive taxation of business income. Such simplified tax regimes can reduce the relatively high compliance costs of micro and small enterprises, which might otherwise discourage entrepreneurs from formalizing their activities and paying taxes. The note addresses design issues for a turnover tax regime—which taxes it replaces, what the criteria are for eligibility, how to determine the optimal threshold, and how to set the tax rate. A key observation is that, although low turnover tax rates may incite larger firms to artificially reduce their sales, the rate should also not be so high as to discourage formalization of activities. A table of tax rates and turnover thresholds observed internationally is provided. The note concludes by suggesting analytical steps to guide practitioners in designing turnover tax regimes.
Keywords:
Presumptive tax; turnover tax; informal sector; microenterprises; taxpayer Compliance cost; turnover tax rate; turnover tax systems; IMF library; Sales tax; Income and capital gains taxes; Income tax systems; Corporate income tax; Effective tax rate; Africa; South America; Eastern Europe; West Africa; Western Europe
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 IMF How To Notes
How to Design a Regional Tax Treaty and Tax Treaty Policy Framework in a Developing Country
Kiyoshi Nakayama
A well-designed regional tax treaty to which developing countries are signatories will include provisions securing minimum withholding taxes on investment income and technical service fees, a taxing right in respect of capital gains from indirect offshore transfers, and guarding against-treaty shopping. A tax treaty policy framework—national or regional—that specifies the main policy outcomes to be achieved before negotiations commence would enable developing countries with more limited expertise and lower capacity for tax treaty negotiations to avoid concluding problematic tax treaties. This note provides guidance for members of regional economic communities in the developing world on what should and should not be included in a regional tax treaty and how to design on a common tax treaty policy framework for use in negotiations of bilateral tax treaties with nonmembers.
Keywords:
value-added tax; corporate tax; regional tax; regional tax policy; regional tax treaty; developing countries; tax treaty; group treaty negotiations; tax treaty position; treaty negotiations; treaty shopping; Double taxation; Withholding tax; Payroll tax; Corporate income tax; Dividend tax; Caribbean; West Africa
Cover IMF Working Papers
Tax Policy and Inclusive Growth
Ruud A. de Mooij
This paper discusses the theory and practice of tax design to achieve an efficient and equitable outcome, i.e. in support of inclusive growth. It starts with a discussion of the key principles from tax theory to guide practical tax design. Then, it elaborates on more granular tax policy, discussing key choices in the structure of the personal income tax on labor and capital income, taxes on wealth, the corporate income tax, and consumption taxes. The paper concludes by highlighting the political economy considerations of the issues with concrete recommedtions as to how to implement tax reform.
Keywords:
tax policy; inclusive growth; inequality; poverty; income distribution; WP; economic rent; personal income; tax liability; cost of capital; external cost; public finance; rate of return; low income; take-home pay; Income; Capital income tax; Income and capital gains taxes; Corporate income tax; Income tax systems; Europe; Global