Business and Economics > International Taxation

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International Monetary Fund

Abstract

This report overviews countries fiscal actions in response to COVID-19 and discusses how governments policies should adapt to get ahead of the pandemic and set the stage for a greener, fairer, and more durable recovery. Global vaccination should be scaled up as it can save lives and will eventually pay for itself with stronger employment and economic activity. Until the pandemic is brought under control globally, fiscal policies must remain flexible and supportive, while keeping debt at a manageable level over the long term. Governments also need to adopt comprehensive policies, embedded in medium-term frameworks, to tackle inequalities—especially in access to basic public services—that were exacerbated by the COVID-19 pandemic and may cause income gaps to persist. Investing in education, healthcare and early childhood development and strengthening social safety nets financed through improved tax capacity and higher progressivity, can strengthen lifetime opportunities, improve trust, and contribute to more social cohesion.

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.

Mr. Shafik Hebous and Mr. Alexander D Klemm
Profit shifting by multinational enterprises—through manipulation of transfer prices of related-party trade, intragroup lending, or the location of intangibles—affects international flows, raising the question of its impact on the current account and external balances. This paper approaches this question theoretically and empirically. In theory, profit shifting distorts the components of the current account and bilateral current account balances but leaves a country’s aggregate net balance unaffected. There is, however, a real effect on current account balances, because taxes are paid to different jurisdictions. Moreover—in practice—the measured current account could change, because not all transactions are equally easy to track. Our panel empirical results broadly confirm that the current account balance tends to be, on average, unaffected by profit shifting, but taking heterogeneity into account we find that both the real tax effect and mismeasurement strengthen income balances—and thus the current account—in investment hubs.
John Brondolo, Joshua Aslett, and Andja Komso
This technical note and manual (TNM) addresses the following questions: What is a business continuity plan (BCP) and what are its main components? What are a BCP’s key design considerations for an epidemic? What are the organizational and management arrangements for a BCP? How does a BCP maintain a tax agency’s critical functions during an epidemic? and How does a tax agency keep its BCP current and ready for deployment?
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.
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.
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.
International Monetary Fund. Fiscal Affairs Dept. and International Monetary Fund. Legal Dept.
The policy paper Corporate Taxation in the Global Economy stresses the need to maintain and build on the progress in international cooperation on tax matters that has been achieved in recent years, and in some respects now appears under stress. With special attention to the circumstances of developing countries, the paper identifies and discusses various options currently under discussion for the international tax system to ensure that countries, and in particular low-income countries, can continue to collect corporate tax revenues from multinational activities.
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.
International Monetary Fund. African Dept.
This Selected Issues paper describes Uganda’s experience under the 2013 Policy Support Instrument (PSI). The current 2013 PSI was approved by the IMF’s Executive Board in June 2013 with an initial duration of three years. Overall, performance under this PSI has been assessed to be satisfactory. Most quantitative assessment criteria were met, and macroeconomic stability maintained. However, the pace of structural reforms slowed down compared with the past, and only about half of the structural benchmarks were ultimately met. The experience shows the importance of ensuring commitment to the reforms, explaining them better, and getting broad-based buy-in to achieve progress.