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Europe > Ireland

You are looking at 1 - 8 of 8 items for :

  • Type: Journal Issue x
  • International Taxation x
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Cover Technical Notes and Manuals
The Case for (and Against) Asset Management Companies in Banking Crises
Miguel A Otero Fernandez
,
Jaime Ponce
,
Marc C Dobler
, and
Tomoaki Hayashi
This technical note explores the advantages and disadvantages of establishing state-sponsored centralized asset management companies (AMCs) to address high levels of bank asset distress during financial crises. AMCs may offer potential benefits like mitigating downward price spirals or achieving efficiency gains by consolidating creditor claims and scarce expertise. However, significant risks and costs warrant careful consideration. These include extreme uncertainties in asset valuation and substantial operational and financial risks. Past international experiences highlight the dangers of underestimating these risks, potentially turning the AMC into a mechanism for deferring losses to taxpayers, rather than minimizing them, and ultimately increasing long-term public costs and moral hazard. This technical note emphasizes these trade-offs and discusses crucial design elements for effective AMCs: a clear mandate, transfer pricing that prudently reflects asset values and disposal costs, strong governance with independent management, and efficient operational processes promoting transparency and accountability.
Keywords:
Asset Management Company (AMC); Bank resolution; Financial Crisis; Financial regulation and supervision; Problem Asset Resolution; Non-performing Loans; Bank restructuring.; asset price spiral; centralized asset management companies; give borrower; AMC need; AMC debt; bank asset distress; resolution strategy; recovery value; asset characteristic; Asset management companies; Distressed assets; Nonperforming loans; Asset valuation; Loans; Global
Cover Technical Notes and Manuals
Special Purpose Entities: Guidelines for a Data Template
Mr. Carlos Sanchez-Munoz
,
Artak Harutyunyan
, and
Ms. Padma S Hurree Gobin
The Note is meant to assist compilers in the practical application of the agreed defini¬tion to identify resident Special Purpose Entities (SPE) in their jurisdictions and in collecting and reporting SPE-related cross-border data. To this end, these guidelines provide practical advice on the (1) implementa¬tion of the definition of SPEs, (2) possible data sources and processes for collecting and compiling SPE-related statistics, and (3) reporting within the agreed Data Template.
Keywords:
Globalization; multinationals; host jurisdictions; institutional units; control; cross-border flows and positions; SPE definition; SPE data collection; company B; SPE flow; SPE statistics; Special purpose vehicle; Data collection; External sector statistics; Foreign direct investment; International investment position; 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 Technical Notes and Manuals
How to Assess Country Risk: The Vulnerability Exercise Approach Using Machine Learning
International Monetary Fund. Strategy, Policy, & Review Department
The IMF’s Vulnerability Exercise (VE) is a cross-country exercise that identifies country-specific near-term macroeconomic risks. As a key element of the Fund’s broader risk architecture, the VE is a bottom-up, multi-sectoral approach to risk assessments for all IMF member countries. The VE modeling toolkit is regularly updated in response to global economic developments and the latest modeling innovations. The new generation of VE models presented here leverages machine-learning algorithms. The models can better capture interactions between different parts of the economy and non-linear relationships that are not well measured in ”normal times.” The performance of machine-learning-based models is evaluated against more conventional models in a horse-race format. The paper also presents direct, transparent methods for communicating model results.
Keywords:
Risk Assessment; Supervised Machine Learning; Prediction; Sudden Stop; Exchange Market Pressure; Fiscal Crisis; Debt; Financial Crisis; Economic Crisis; Economic Growth; VE modeling toolkit; ML technique; Vulnerability Exercise approach using machine learning; IMF's Vulnerability Exercise; ML tool; crisis risk indices; Early warning systems; Global financial crisis of 2008-2009; Sudden stops; Banking crises; 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 Working Papers
Can Contingent Convertibles Help Private Asset Managers Fund Their Acquisition of Non-Performing Loans from Portuguese Banks?
Mr. Andre O Santos
This paper analyzes the capital structure of private asset managers in which the acquisition of nonperforming loans (NPLs) is funded with Contingent Convertibles (CoCos) placed with investors. The paper develops a model based on NPL transfer prices and residual recovery rates to assess capital structures consisting of CoCos and equity. The CoCos would contain put and call options to write down losses and write up profits, respectively, arising from liquidation and restructuring procedures. The paper concludes that the protection mechanism provided by debt write-downs embedded in CoCos and the incentives to investors provided by debt write-ups could help bridge the gap between Portuguese banks’ NPL bid prices and private equity firms’ ask prices.
Keywords:
WP; coupon rate; capital structure; book value; maturity date; Asset managers; contingent convertibles; asset pricing; nonperforming loans; recovery rate; NPL sale; debt write-up; portfolio acquisition; NPL securitization; Loans; Transfer pricing; Contingent convertible capital; Stocks; Global
Cover IMF Staff Country Reports
Ireland: Background Papers
International Monetary Fund
This paper considers elements of macroeconomic policy central to Ireland’s objective of being among the first countries to enter into European Economic and Monetary Union. The paper analyzes the main determinants of the Irish pound/sterling exchange rate, an issue brought to the fore by the currency turbulence of March 1995, which saw a sterling-inspired decline in the Irish pound against the deutsche mark. It also considers fiscal developments and prospects, highlighting tax reform measures undertaken to accelerate job creation, the growth of spending in recent years, and the medium-term fiscal outlook.
Keywords:
ISCR; CR; GATT agreement; estimate; GATT; GATT Uruguay Round agreement; HP estimates of the output gap; computing output gaps; trade hostility; Real exchange rates; Transfer pricing; Output gap; Current spending; General Agreement on Tariffs and Trade; Global