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Recent developments - including greater taxpayer sophistication in structuring and locating international financing arrangements, increased government concerns with the role of debt in sophisticated tax avoidance techniques, and disruption by decisions of the European Court of Justice of member...
Persistent link: https://www.econbiz.de/10014215233
This article deals with the decision taken by the Court of Justice of the European Union in X (Case C-283/15), on 9 February 2017. In general terms, the Court followed the Opinion of Advocate General Wathelet of 7 September 2016.The case concerned tax legislation permitting the deduction of...
Persistent link: https://www.econbiz.de/10014031792
This study is focused on the tax measures that have been enacted in Portugal, following the health and economic crisis created by the SARS-CoV-2/COVID-19 pandemic.First, it aims at comprehensively characterizing the measures enacted, structuring them by thematic clusters, enabling the reader to...
Persistent link: https://www.econbiz.de/10013247781
In recent years, the European Court of Justice (ECJ) has invalidated many income tax law provisions of EU member states as violating the guarantees of the European constitutional treaties of freedom of movement for goods, services, persons, and capital. These decisions have not, however, been...
Persistent link: https://www.econbiz.de/10014059579
We consider a world in which countries apply optimal taxes on mobile capital and savings (like in Bucovetsky and Wilson, 1991). Firms and savers may underreport income in order to avoid or evade taxation. We show that, even in the presence of underreporting, the equilibrium under tax competition...
Persistent link: https://www.econbiz.de/10012625748
In this report, Fleming, Peroni, and Shay analyze the effects of including a final, low-rate minimum tax on U.S. multinational corporations in a territorial system. They continue to prefer a real worldwide international tax system, but see a final, low-rate minimum tax as a second-best measure...
Persistent link: https://www.econbiz.de/10012932629
In this paper, we discuss the hypothetical impact of the Amount A regime on US corporate income tax revenue. The general outline of the two-pillar taxation system, which includes Amount A as a part of Pillar One, was agreed upon in October 2021 by the Inclusive Framework delegates who tackled...
Persistent link: https://www.econbiz.de/10013294603
[EN] “Should I stay or should I go… ”? The implementation of the EU’s internal market, characterized in the Treaty on the functioning of the European Union ( TFUE) as ”an area without internal frontiers in which the free movement of goods, persons, services and capital is ensured”,...
Persistent link: https://www.econbiz.de/10013312936
We consider a world in which countries apply optimal taxes on mobile capital and savings (like in Bucovetsky and Wilson, 1991). Firms and savers may underreport income in order to avoid or evade taxation. We show that, even in the presence of underreporting, the equilibrium under tax competition...
Persistent link: https://www.econbiz.de/10013211117
In this paper we use a panel of 189 countries to describe the salient trends that have emerged in national personal income tax systems spanning the twenty five year period from 1981 to 2005. Using complete national income tax schedules, we calculate actual average and marginal tax rates at...
Persistent link: https://www.econbiz.de/10010269377