This paper presents a new approach to estimating the existence and magnitude of tax-motivated income shifting within multinational corporations. Existing studies of income shifting use changes in corporate tax rates as a source of identification. In contrast, this paper exploits exogenous...

For several years, a debate has swirled around the taxation of hedge fund managers' compensation. Because it is structured as a type of partnership interest in the hedge fund, hedge fund managers may be eligible to pay taxes at lower capital gains rates on a large percentage of their income from...

Where a parent company owns a controlling interest in a subsidiary resident in another Member State the question arises whether article 43 EC Treaty (the freedom of establishment), article 56 EC Treaty (the free movement of capital), or both articles may be relied upon by the taxpayer to...

The reform process for the indirect taxation regime in India has been ongoing for some time, with the prevailing view being that simplification of tax regime and a principle-laden approach was an essential concomitant in the outlook of a developed nation. Much debate has ensued and during the...

The Government of India submitted the ‘Direct Taxes Code' Bill, 2010 the Parliament in August, 2010. The Code, expected to come into force from the next financial year i.e. 1st April 2012, is not just a regular amendment but replaces all the existing direct tax laws in India. The drafters have...

Section 11 applies a bracket system to corporations, imposing lower tax rates on lower amounts of corporate income. Similarly, section 1 applies a bracket system to individuals. The bracket system in section 1 is intended to adjust the tax rate to the taxpayer's standard of living. Modest and...

Project Merlin – the agreement between the UK Government and some major banks – has started the move towards the reform of important banking issues in the UK. One of the reasons for opting for a non-binding agreement instead of hard law is the assumption that the banks may perceive high...

The author, in this article, examines Japan's Tax Reform 2009/10, with special reference to the background to the reform, the relevant legislative amendments regarding the taxation of controlled foreign subsidiaries and the implications of the reform for the future

This article recommends allowing a lessor and a lessee to decide between themselves which party will be entitled to the tax benefit associated with the ownership of the leased property. It describes why the current linkage of tax benefits to property ownership is economically inefficient and...

The European Commission is currently working on a legislative draft to harmonise corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a set of rules...