Narrow Your Choices

Refine By Countries

Refine By Series

Refine By Language

Refine By Date

—

Refine By IMF Taxonomy

Refine By JEL Taxonomy

Refine by LOC Taxonomy

Refine By THEMA Taxonomy

  • Print
  • Save

Business and Economics > Corporate Taxation

You are looking at 1 - 10 of 20 items for :

  • Type: Journal Issue x
  • Double taxation x
Clear All Modify Search
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 Policy Papers
International Corporate Tax Reform
International Monetary Fund. Fiscal Affairs Dept.
and
International Monetary Fund. Legal Dept.
To relieve the pressure on the outdated international corporate tax system, an ambitious reform was agreed at the Inclusive Framework (IF) on Base Erosion and Profit Shifting in 2021, with now 138 jurisdictions joining. It complements previous efforts to mitigate profit shifting by addressing the challenges of the digitalization of the economy through a new allocation of taxing rights to market economies (Pillar 1) and tax competition through a global minimum corporate tax (Pillar 2). This paper concludes that the agreement makes the international tax system more robust to tax spillovers, better equipped to address digitalization, and modestly raises global tax revenues.
Keywords:
Tax Policy; allocation rule; IMF capacity development; tax competition; G. revenue mobilization agenda; A. reform direction; International tax issues; Corporate income tax; Double taxation; Tax incentives; Global
Cover Departmental Papers
Taxing Multinationals in Europe
Ernesto Crivelli
,
Ruud A. de Mooij
,
J. E. J. De Vrijer
,
Mr. Shafik Hebous
, and
Mr. Alexander D Klemm
This paper aims to contribute to the European policy debate on corporate income tax reform in three ways. First, it takes a step back to review the performance of the CIT in Europe over the past several decades and the important role played by MNEs in European economies. Second, it analyses corporate tax spillovers in Europe with a focus on the channels and magnitudes of both profit shifting and CIT competition. Third, the paper examines the progress made in European CIT coordination and discusses reforms to strengthen the harmonization of corporate tax policies, in order to effectively reduce both tax competition and profit shifting.
Keywords:
Europe; International taxation; Corporate taxation; Multinational corporations; Corporate profits; Tax competition; MNE profits; revenue effect; EU code of conduct; effects of the CCCTB reform; profit shifting; Corporate income tax; Corporate taxes; Competition; Formula apportionment; 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
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
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
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 Policy Papers
Fiscalité des entreprises dans l'économie mondiale
International Monetary Fund. Fiscal Affairs Dept.
and
International Monetary Fund. Legal Dept.
Le document Fiscalité des entreprises dans l'économie mondiale insiste sur la nécessité de préserver et de mettre à profit les progrès de la coopération fiscale internationale accomplis ces dernières années qui, sur certains points, sont actuellement menacés. Le document accorde une attention particulière à la situation des pays en développement, et examine plusieurs options envisagées pour que les pays, en particulier les pays à faible revenu, puissent continuer de recouvrer des impôts sur les bénéfices tirés d'activités multinationales.
Keywords:
PP; OECD BEPS project; tax; director; IMF executive board review; tax competition
Cover Policy Papers
Tributación internacional de empresas
International Monetary Fund. Fiscal Affairs Dept.
and
International Monetary Fund. Legal Dept.
El documento «Tributación internacional de empresas» resalta la necesidad de mantener y promover los avances logrados en los últimos años en el terreno de la cooperación internacional sobre cuestiones tributarias, que en algunos sentidos parecen estar ahora sujetos a tensiones. Prestando especial atención a las circunstancias de los países en desarrollo, enumera y analiza distintas opciones en estudio para el sistema de tributación internacional que buscan asegurar que los países —sobre todo los de bajos ingresos— puedan continuar recaudando impuestos sobre las actividades multinacionales de las empresas.
Keywords:
PP; OECD BEPS project; tax; director; IMF executive board review; tax competition