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Business and Economics > Corporate Taxation

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Cover IMF Working Papers
A Destination-Based Allowance for Corporate Equity
Mr. Shafik Hebous
and
Mr. Alexander D Klemm
Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.
Keywords:
WP; interest rate; capital stock; Destination-Based Taxation; ACE; ACC; investment goods; notional interest rate; tax competition; interest receipt; competition policy tool; rate of return; border tax; depreciation rate; upfront tax cost; tax saving; Allowance for corporate equity; Value-added tax; Stocks; Discount rates; Corporate income tax; Global; Destination-based allowance; copyright Page; B. profit shifting; based allowance; E. exchange rate
Cover Technical Notes and Manuals
Fiscal Analysis of Resource Industries: (FARI Methodology)
Ms. Oana Luca
and
Diego Mesa Puyo
This manual introduces key concepts and methodology used by the Fiscal Affairs Department (FAD) in its fiscal analysis of resource industries (FARI) framework. Proper evaluation of fiscal regimes for extractive industries (EI) requires economic and financial analysis at the project level, and FARI is an analytical tool that allows such fiscal regime design and evaluation. The FARI framework has been primarily used in FAD’s advisory work on fiscal regime design: it supports calibration of fiscal parameters, sensitivity analysis, and international comparisons. In parallel to that, FARI has also evolved into a revenue forecasting tool, allowing IMF economists and government officials to estimate the composition and timing of expected revenue streams from the EI sector, analyze revenue management issues (including quantification of fiscal rules), and better integrate the EI sector in the country macroeconomic frameworks. Looking forward, the model presents a useful tool for revenue administration practitioners, allowing them to compare actual, realized revenues with model results in tax gap analysis.
Keywords:
TNM; income tax; discount rate; cash flows; capital expenditure; withholding tax; Mining taxation; petroleum taxation; fiscal regime design; profit petroleum; Project net cash flows; payback period; internal rate of return; cost of capital; Currencies; Oil; Corporate income tax; Discount rates; Fiscal Analysis of Resource Industries (FARI); Africa