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Business and Economics > Corporate Taxation

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Cover IMF How To Notes
How to Combat Value-Added Tax Refund Fraud
Cedric Andrew
and
Ms. Katherine Baer
A previous IMF Working Paper on value-added tax (VAT) refunds (WP/07/31, by Keen and Smith) describes the main forms of VAT noncompliance and concludes that VAT is susceptible to evasion and fraud like any other tax. This paper shows the insidious nature and extent of VAT refund fraud in selected EU countries and argues that this type of noncompliance requires tax administrations to adopt a coordinated strategy and deploy a range of countermeasures to combat this threat. Because such fraud is primarily a criminal legal issue, tackling it successfully will require cooperation, both internationally between VAT administrations and nationally between tax authorities and the judiciary. The paper’s focus is primarily on advanced economies in the context of the EU, but many of the recommendations are applicable to emerging market and developing countries. A separate IMF How to Note discusses managing VAT refunds in developing countries.
Keywords:
value-added tax; refund; fraud; strategies; cooperation; refund fraud; acquisition fraud scheme; return fraud; MTIC VAT Contra carousel scheme; Customs and Excise tax office case study; Tax refunds; Tax administration core functions; Middle East
Cover IMF Staff Country Reports
Guinea: Selected Issues
International Monetary Fund. African Dept.
Selected Issues
Keywords:
B. mining revenue; revenue management; tax exemption; A. mining revenue; company Cost Structure; Mining sector; Oil; gas and mining taxes; Corporate income tax; Transfer pricing; Natural resources; Asia and Pacific; Global
Cover IMF Staff Country Reports
Guinea: Selected Issues
International Monetary Fund. African Dept.
Selected Issues
Keywords:
B. mining revenue; revenue management; tax exemption; A. mining revenue; company Cost Structure; Mining sector; Oil; gas and mining taxes; Corporate income tax; Transfer pricing; Natural resources; Asia and Pacific; 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 Corporate Income Taxes under Pressure
Corporate Income Taxes under Pressure
Why Reform Is Needed and How It Could Be Designed
Ruud A. de Mooij
,
Mr. Alexander D Klemm
, and
Ms. Victoria J Perry

Abstract

The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.

Keywords:
Profit shifting; tax competition; tax avoidance; international cooperation; tax reform; multinationals; digitalization; multinational enterprise; tax treaty; passive income; Corporate income tax; Double taxation; Income; Foreign direct investment; Corporate taxes; Global; Sub-Saharan Africa; Europe
Cover IMF Working Papers
Is There Money on the Table? Evidence on the Magnitude of Profit Shifting in the Extractive Industries
Sebastian Beer
Profit shifting remains a key concern in international tax system debate, but discussions are largely based on aggregate estimates, with less attention paid to individual sectors. Drawing on a novel dataset, we quantify tax avoidance risks in the extractive industries, a sector which is revenue critical for many developing economies. We find that a one percentage point increase in the domestic corporate tax rate has historically reduced sectoral profits by slightly over 3 percent; and the response tends to be more pronounced among mining than among hydrocarbon firms. There is only weak evidence transfer pricing rules contain tax minimization efforts of MNEs in our sample, but interest limitation rules (e.g., thin capitalization or earnings based rules) do reduce the observable extent of profit shifting. Our findings highlight the challenge of taxing income in the natural resource sector and suggest how fiscal regime design might be strengthened.
Keywords:
International Corporate Taxation; Multinational Firms; Mining; Petroleum; Profit Shifting; Debt; Interest Limitations; Transfer Pricing; Production Sharing Agreements; WP; tax rate differential; taxable profits; CIT base; profits increase; representative firm
Cover IMF Working Papers
The Impact of Profit Shifting on Economic Activity and Tax Competition
Mr. Alexander D Klemm
and
Ms. Li Liu
A growing empirical literature has documented significant profit shifting activities by multinationals. This paper looks at the impact of such profit shifting on real activity and tax competition. Real activity can be affected as profit shifting changes—and theoretically most likely reduces—the cost of capital. Tax competition, even over real capital, is affected, because a permissive attitude toward profit shifting can be seen as a selective tax reduction for multinationals. Tightening profit shifting rules in turn can affect tax competition through the main rate. This paper discusses these issues theoretically and with the help of a simulation to assess the impact of profit-shifting on investment, revenues, and government behavior. Using the theoretical framework, it also provides a brief overview of the related empirical literature.
Keywords:
WP; cost of capital; profit shifting; profit; tax competition; BEPS; profit-shifting opportunity; profit reallocation; costless profit; production function; optimization problem; Thin capitalization rules; Transfer pricing rules; Corporate income tax; Anti-avoidance rules; Global
Cover IMF Working Papers
At A Cost: the Real Effects of Transfer Pricing Regulations
Ruud A. de Mooij
and
Ms. Li Liu
Unilateral adoption of transfer pricing regulations may have a negative impact on real investment by multinational corporations (MNCs). This paper uses a quasi-experimental research design, exploiting unique panel data on domestic and multinational companies in 27 countries during 2006-2014, to find that MNC affiliates reduce their investment by over 11 percent following the introduction of transfer pricing regulations. There is no significant reduction in total investment by the MNC group, suggesting that these investments are most likely shifted to affiliates in other countries. The impact of transfer pricing regulations corresponds to an increase in the ``TPR-adjusted'' corporate tax rate by almost one quarter.
Keywords:
WP; parent company; cost of capital; gross investment; tax rate; profit shifting; foreign direct investment; corporate tax policy; multinational firms; MNC investment; company group; investment response; ratio variable; MNC group; Transnational corporations; Transfer pricing rules; Corporate income tax; Transfer pricing; Thin capitalization rules; Global
Cover International Taxation and the Extractive Industries
International Taxation and the Extractive Industries

Abstract

The taxation of extractive industries exploiting oil, gas, or minerals is usually treated as a sovereign, national policy and administration issue.This book offers a uniquely comprehensive overview of the theory and practice involved in designing policies on the international aspects of fiscal regimes for these industries, with a particular focus on developing and emerging economies. International Taxation and the Extractive Industries addresses key topics that are not frequently covered in the literature, such as the geo-political implications of cross-border pipelines and the legal implications of mining contracts and regional financial obligations. The contributors, all of whom are leading researchers with experience of working with governments and companies on these issues, present an authoritative collection of chapters. The volume reviews international tax rules, covering both developments in the G20-OECD project on ’Base Erosion and Profit Shifting’ and more radical proposals, identifying core challenges in the extractives sector. This book should become a core resource for both scholars and practitioners. It will also appeal to those interested in international tax issues more widely and those who study environmental economics, macroeconomics and development economics

Keywords:
BOOK; country; tax; government; taxation of multinational; implementation phase; revenues from the extractive industry; tax competition; revenue base; Transfer pricing; Oil; Double taxation; Income and capital gains taxes; Corporate income tax; Global; Europe; Sub-Saharan Africa; Middle East; Africa; transit country; access fee; tax authorities; transit fee; West Africa
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