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Business and Economics > Corporate Taxation

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Cover IMF Staff Country Reports
Ireland: Selected Issues
International Monetary Fund. European Dept.
This Selected Issues paper provides an international perspective to the authorities’ two recent policy measures: setting up new savings and counter cyclical and climate infrastructure funds and reforming the judicial review of planning decisions in Ireland. The first essay presents international best practices in the design and operation of sovereign wealth funds that could inform the setup of the two new funds in Ireland. It highlights the importance of operating the funds within a strong fiscal policy framework. The second essay reviews Ireland’s planning and permitting system, underscoring the key elements that have hindered public investment. It also looks into the government’s proposed Bill to reform the planning system and contrasts its key features with those of other international jurisdictions. It finds that several issues may contribute to the inefficiencies in the planning and judicial review system, such as the loose standing requirements and lack of mandatory timelines related to judicial review, as well as institutional governance issues within the planning board, which the newly proposed reforms and legislative measures seek to address.
Keywords:
housing affordability; D. policy option; savings fund; modernizing judicial review; impulse response; Housing; Housing prices; Pension spending; Global
Cover IMF Staff Country Reports
Ireland: 2023 Article IV Consultation-Press Release; and Staff Report
International Monetary Fund. European Dept.
This 2023 Article IV Consultation highlights that Ireland’s economy has shown remarkable resilience in the face of consecutive shocks. The Irish economy has displayed remarkable resilience in the face of recent consecutive shocks and is well-positioned to achieve a soft landing. Growth is expected to moderate to a still solid level in 2023-24, from a very high base, as tighter financial conditions, domestic capacity constraints, and weakening external demand weigh on the economy. Continued fiscal prudence is warranted to complement monetary tightening in sustaining disinflation and to build adequate buffers for the future. As fiscal policy should avoid adding to aggregate demand amid still elevated inflation, tax revenue over performance should be saved. The 2023 fiscal stance is appropriate. Fiscal policy should support growth-enhancing investment and broaden the tax base. The authorities’ decision to save part of excess corporate income tax revenues in two savings funds is welcome. Tighter financial conditions, persistent inflation, and rising vulnerabilities in the commercial real estate market with linkages to leveraged non-banks call for continued heightened vigilance of financial stability risks.
Keywords:
liability positions vis-à-vis nonresident; inflation development; transparency policy; money market rate; quarterly balance of payments; growth-enhancing investment; Medium-term fiscal policy; persistent inflation; Ireland's economy; Housing; Inflation; Corporate income tax; Credit; Global
Cover IMF Staff Country Reports
Ireland: Selected Issues
International Monetary Fund. European Dept.
This Selected Issues paper on Ireland focuses on ensuring an inclusive and growth-enhancing fiscal policy mix. It assesses the scope for improving the tax system toward a more growth-friendly structure, and for achieving efficiency gains in public expenditure. It also discusses upcoming impediments to long term fiscal sustainability and proposes options to achieve a more growth friendly and equity-enhancing revenue and expenditure policy mix. Under the 2021 National Development Plan, the government plans to significantly expand investment to historically high levels over the medium term. Good progress has been achieved in raising public spending efficiency but there is scope for further improvement. The stylized facts highlight the need for reforms to broaden the tax base and find new and stable sources of revenues as well as improving public expenditure efficiency. Public spending should focus on growth-friendly spending and reducing efficiency gaps. Decisive reforms are needed to ensure the future sustainability of the pension system and safeguard long term fiscal sustainability.
Keywords:
expenditure needs; GROWTH-ENHANCING fiscal policy mix; disparity in Ireland; spending pressure; OECD housing affordability database; Income inequality; Income; Corporate income tax; 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 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 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
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 Staff Country Reports
Ireland: 2019 Article IV Consultation-Press Release; Staff Report; and Statement by the Executive Director for Ireland
International Monetary Fund. European Dept.
The Irish economy continues to expand strongly, benefitting from higher net exports by multinational enterprises and robust domestic demand. Accelerating wage growth reflects tight labor market conditions and inflation has started to pick up. Crisis legacies have diminished but some vulnerabilities persist. The outlook remains broadly positive, provided Brexit proceeds in an orderly manner. However, the economy operates near full capacity and an accelerating cyclical momentum could re-ignite a boom-bust dynamic. A no-deal Brexit represents the key downside risk, while escalation in global protectionism and sudden changes in corporate tax planning of multinational enterprises in Ireland could adversely affect the economy and public finances.
Keywords:
ISCR; CR; government; Ireland; headline inflation; housing supply strategy; central bank of Ireland; liability positions vis-à-vis nonresident; welfare benefits system; IMF staff; potential GDP; Corporate income tax; Housing; Financial sector; Credit; Global; Europe
Cover IMF Staff Country Reports
Ireland: Selected Issues
International Monetary Fund. European Dept.
This Selected Issues paper estimates the cyclical position of the Irish economy. Assessing the business cycle in Ireland is complicated by the open character of its labor market and large presence of globally active multinationals. However, analysis suggests that the Irish economy is in the midst of a cyclical upswing. All methods suggest a positive output gap in 2017, while the labor market shows signs of upward wage pressures, as net immigration has been weak so far. These signs are consistent with a cyclical upswing, amid strong estimated potential output growth, and point to risks of a boom-bust cycle, should the economy continue to push the growth momentum.
Keywords:
ISCR; CR; commercial real estate; price; CRE price; labor force gap; growth labor force growth; exit tax; CRE market; Labor force; Corporate income tax; Personal income; Labor markets; Unemployment rate; Global; Europe
Cover IMF Staff Country Reports
Ireland: 2018 Article IV Consultation-Press Release; Staff Report; and Statement by the Executive Director for Ireland
International Monetary Fund. European Dept.
This 2018 Article IV Consultation highlights that the Irish economy continues to grow at a rapid pace, well above the European Union average. Although headline data are distorted by the volatility of multinationals’ activity, the broad recovery of (modified) domestic demand (4 percent in 2017) underpins the expansion. Strong labor market performance brought the unemployment rate down to below 6 percent by April 2018. Although wage pressures emerged in some sectors, inflation remained subdued, mainly reflecting the pass-through of pound sterling depreciation. Public finances continued to improve on the back of strong output growth, while the public debt burden declined slightly to 68 percent of GDP. The outlook remains broadly positive but with externally-driven downside risks.
Keywords:
ISCR; CR; market; proceeds; headline inflation; government; public finance; liability positions vis-à-vis nonresident; housing demand; government priority; crisis legacy issue; demand pressure; labor market condition; Housing; Housing prices; Corporate income tax; Income; Global