ERN: Taxation最新文献_第2页

Public Debt Expansions and the Dynamics of the Household Borrowing Constraint 公共债务扩张和家庭借贷约束的动态

ERN: Taxation Pub Date : 2020-03-18 DOI: 10.2139/ssrn.3612932

V. Ercolani, António R. Antunes

引用次数: 80

The Impact of International Tax Information Exchange Agreements on the Use of Tax Amnesty: Evidence from Norway 国际税收信息交换协议对税收特赦使用的影响:来自挪威的证据

ERN: Taxation Pub Date : 2019-09-30 DOI: 10.2139/ssrn.3464252

Jonas Andersson, F. Schroyen, Gaute Torsvik

{"title":"The Impact of International Tax Information Exchange Agreements on the Use of Tax Amnesty: Evidence from Norway","authors":"Jonas Andersson, F. Schroyen, Gaute Torsvik","doi":"10.2139/ssrn.3464252","DOIUrl":"https://doi.org/10.2139/ssrn.3464252","url":null,"abstract":"In this paper we develop a model for tax amnesty applications in a multi-period setting. One key insight from the model is that applying for amnesty becomes more attractive at the moment when stricter enforcement is announced, even if the implementation of the policy is in the distant future. We use our model to make sense of how international tax information exchange agreements affects voluntary disclosure of wealth and income previously hidden in tax havens. Our data is from Norway. In accordance with the dynamic amnesty model we observe a strong announcement effect of a tax information exchange agreement between Norway and Switzerland and Luxembourg, the two most important tax havens for Norwegian tax evaders. However, the effect levels off very quickly, much faster than our model predicts. We think this is because the initial announcement of the tax agreement exaggerated the risk the agreement imposed to those who had hidden taxable income and wealth in Switzerland. We also estimate and find significant effects of the press releases the Norwegian Tax Authority issues to inform taxpayers about new international tax agreements and the amnesty, or voluntary disclosure, option that exists in the Norwegian tax code.","PeriodicalId":105680,"journal":{"name":"ERN: Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2019-09-30","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"130025962","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 12

Hidden Wealth 隐藏的财富

ERN: Taxation Pub Date : 2019-09-01 DOI: 10.2139/ssrn.3470253

N. Cummins

引用次数: 2

Eliminating the Tax Shield Through Allowance for Corporate Equity: Cross-Border Credit Supply Effects 通过公司股权补贴消除税收屏蔽:跨境信贷供给效应

ERN: Taxation Pub Date : 2019-07-18 DOI: 10.2139/ssrn.3271366

Swarnava Biswas, Bálint Horváth, Wei Zhai

引用次数: 6

US Corporate Tax Cuts: Spillovers to the Irish Economy 美国企业减税:对爱尔兰经济的溢出效应

ERN: Taxation Pub Date : 2019-06-21 DOI: 10.2139/ssrn.3418183

Daragh Clancy

引用次数: 0

OECD-Led Tax Reforms: A Prescription for a Less Competitive Economy 经合组织主导的税收改革:降低经济竞争力的药方

ERN: Taxation Pub Date : 2019-06-18 DOI: 10.2139/ssrn.3406260

Constantin Gurdgiev

引用次数: 1

Sovereign Default and Imperfect Tax Enforcement 主权违约和不完善的税收执行

ERN: Taxation Pub Date : 2019-06-01 DOI: 10.2139/ssrn.3400076

Francesco Pappadà, Yanos Zylberberg

引用次数: 2

Why is IFRS Not a Good Starting Point for a Tax Base? 为什么国际财务报告准则不是一个好的税基起点?

ERN: Taxation Pub Date : 2019-05-05 DOI: 10.2139/ssrn.3383061

Antonio Lopo Martinez

引用次数: 1

The International Coordination of Corporate Taxation: Old Solutions for New Challenges? 企业税收的国际协调:新挑战的旧解决方案?

ERN: Taxation Pub Date : 2019-03-10 DOI: 10.2139/ssrn.3395813

Vieri Ceriani, Giacomo Ricotti

{"title":"The International Coordination of Corporate Taxation: Old Solutions for New Challenges?","authors":"Vieri Ceriani, Giacomo Ricotti","doi":"10.2139/ssrn.3395813","DOIUrl":"https://doi.org/10.2139/ssrn.3395813","url":null,"abstract":"The ways in which multinational companies operate in the current economic context questions the adequacy of international coordination of corporate taxation. A conceptual approach would require abandoning the classic paradigms of the international tax system (permanent establishment, arm's length, transfer pricing); they remain at the basis of the “Base Erosion and Profit Shifting” project (BEPS) elaborated by the OECD but are now obsolescent. The crisis of this system has been exacerbated by the Trump Reform and the explosion of the digital economy. The former introduces new regimes that undermine international cooperation and are in contrast with the WTO rules and with the double taxation treaties, regardless of the traditional OECD principles. The latter has features that cannot be governed by current tax rules, even if improved with the suggestions of the BEPS project. Solutions proposed at international level or applied by individual countries could lead to great uncertainty. A rational response to these challenges would rest on different bases, such as those of a system of formulary apportionment, with advantages in terms of simplicity, cost and certainty, fostering allocative efficiency and growth. Although this design is not feasible at international level, applying such a system in Europe, with the common consolidated corporate tax base (CCCTB), could ensure greater attractiveness and efficiency of the EU internal market: it would apply the same formulary system applied to other markets (e.g., the US market), while intra-European transactions are still regulated by the transfer pricing mechanism.","PeriodicalId":105680,"journal":{"name":"ERN: Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2019-03-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116652383","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1

Hybrid Entity Mismatches: Exploring Three Alternatives for Coordination 混合实体不匹配:探索协调的三种选择

ERN: Taxation Pub Date : 2019-01-01 DOI: 10.54648/taxi2019003

L. Parada

{"title":"Hybrid Entity Mismatches: Exploring Three Alternatives for Coordination","authors":"L. Parada","doi":"10.54648/taxi2019003","DOIUrl":"https://doi.org/10.54648/taxi2019003","url":null,"abstract":"The OECD pragmatic approach regarding hybrid entity mismatches is, without doubt, questionable. However, equally questionable is the absence of alternatives solutions proposed by either academics or tax policy makers , which demonstrates a sort of conformism as regards both the diagnosis of the problems and the solutions thereto, as if matching tax outcomes and taxing income somewhere – no matter where – were indeed the only possible path to deal with hybrid entity mismatches. In an attempt to break this inertia, this article argues for coordination in the tax characterization of entities as a straightforward and suitable alternative to replace the current OECD linking rules, and perhaps also, the consequentialist OECD approach to hybrid entity mismatches. For this purpose, three specific alternatives are explored for coordination in the tax characterization of entities, which include (1) supremacy of the tax characterization rules of the source state, (2) supremacy of the tax characterization rules of the residence state and (3) supremacy of the tax characterization rules of the home state. The analysis of these alternatives includes both hypotheticals and specific examples from domestic and supranational laws that are used to illustrate and support their effectiveness. The ultimate aim of this article is to demonstrate that coordination in the tax characterization of entities appears to be not only a more preferable path when compared to the OECD approach of matching tax outcomes, but also a more coherent and less costly alternative for both taxpayers and tax administrations.","PeriodicalId":105680,"journal":{"name":"ERN: Taxation","volume":null,"pages":null},"PeriodicalIF":0.0,"publicationDate":"2019-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"116420724","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}

引用次数: 1