In a recent unanimous decision in the PPL case, the US Supreme Court ruled that a one-timeretroactive British “Windfall Tax” levied on 32 public utilities that were privatised between 1984 and 1996 was eligible for the US foreign tax credit (FTC). The Court rejected the contention of the US...

The tax bias in favour of debt finance under the corporate income tax means that corporate debt ratios exceed the socially optimal level. This creates a rationale for thincapitalization rules limiting the amount of debt that qualifies for interest deductibility. This paper sets up a model of...

This paper focuses on a reduction in the statutory corporate income tax rate. Of course, a reduction in the corporate tax rate would have to be financed by expansion of the corporate tax base, an increase in other taxes, a reduction in spending, and/or an increase in the deficit. The analysis...

This paper assesses the impact of corporate taxation on multinational activity. A numerically solvable general equilibrium model of trade and multinational firms is used to incorporate the following components of corporate taxation: parent and host country statutory corporate tax rates,...

Tax havens have attracted increasing attention from policymakers in recent years. This paper provides an overview of a growing body of research that analyzes the consequences and determinants of the existence of tax haven countries. For instance, recent evidence suggests that tax havens tend to...

This paper reviews economic principles for optimality of the taxation of international profit, from both a global and national perspective. It argues that for traditional systems based on the residence of the investor or the source of the income, nothing less than full harmonisation across...

A substantial empirical literature has grown up in the last two decades, investigating the determinants of flows of capital and the income from capital, and specifically the impact of taxation on such flows. This paper surveys this empirical evidence. Research has progressed rapidly over the...

This paper examines the built-in flexibility properties — as measured by the elasticity of revenue with respect to profits — of the UK corporation tax system. Emphasis is placed on determining some of the major influences on the extent to which total corporation tax revenue changes when...

The European Commission is working on a proposal for a Common Consolidated Corporate Tax Base (CCCTB). A draft Directive is expected to be published during the course of 2008. The proposal aims to tackle some fundamental problems encountered as a result of lack of corporate tax harmonisation,...