Sitting between two stools? Christian Valenduc considers the agreement to reform taxation of multinational companies and asks if the resulting tax system will be stable?

Tax ePub

Moving toward continuous transaction controls CTCs are a concern for multinationals wanting to be VAT compliant. Christiaan van der Valk discusses Transfer pricing of intangible assets Transfer pricing is a common method used for profit shifting. Jay Pil Choi, Jota Ishikawa and Hirofumi Okoshi demonstrate how the ‘arm’s length principle’ may worsen the welfare of high-tax countries
COVID-19 and transfer pricing Stefano Simontacchi, Marco Adda and Francesco Saverio Scandone say that the knock-on effects of the pandemic need to be carefully assessed to understand the potential implications for MNE transfer pricing policies Why India’s tax reforms are big news for international commerce Indirect taxes account for about a third of public revenue. Filippa Jörnstedt examines India's reforms and the use of technology to reduce fraud and increase collection Taxation and development How can countries improve their tax capacity? Vitor Gaspar discusses the role of the MTRS in tax system reform As the globe turns, so does the axle of tax compliance It's important to have a strong working knowledge of the obstacles to tax compliance. Pawel Smolarkiewicz looks at how digital transformation is affecting organisations' approach Tax reforms accelerating with push to lower corporate tax rates Tax Policy Reforms 2018 describes the latest tax reforms. Pascal Saint-Amans says there is a crucial need to continue addressing equity issues and environmental challenges Tax bargaining The OECD estimates that more than $100 billion is lost each year to tax avoidance by MNEs. Peter Egger, Nora Strecker and Benedikt Zoller-Rydzek identify the nature of such bargaining The missing profits of nations Between 1985 and 2018 the global average statutory corporate tax rate fell by more than half. Thomas Tørsløv, Ludvig Wier and Gabriel Zucman argue that profit shifting is a key driver of this decline The GST impact story so far… Aryan Agarwal, Richa Sekhani and Deepanshu Mohan examine the findings of a recent field study on the introduction of the GST, and consider the problems and costs involved Why we should start taxing the robots that are taking human jobs Ryan Abbott and Bret Bogenschneider argue that existing tax policies encourage automation, even when a person would be more efficient, and that automation could lead to reduced government tax revenue Understanding the destination-based approach to business taxation Alan Auerbach argues that a destination-based cash-flow tax would confront the key international problems of existing tax systems Prepare now for Brexit’s tax implications Brexit will have enormous tax implications for companies working in the UK and on the continent. Unless they start preparing now, 2019 will be a major financial and bureaucratic shock, Les Secular writes The Apple tax bill is not protectionism International conflicts are inevitable when governments challenge the excesses of multinational corporations, Sebastian Dullien writes The EU agenda for tax transparency Pierre Moscovici says we are witnessing a generational shift when it comes to tax transparency in the EU and internationally Will Brexit require a re-write of tax legislation? Les Secular considers three areas of international tax where changes may have to be made if there is a Brexit Climate change: putting a price on carbon Kurt Van Dender, Johanna Arlinghaus, Luisa Dressler, Florens Flues and Michelle Harding write that carbon taxes and emissions trading systems will play a more prominent role in the future in cutting emissions Corporate taxation in Europe: let's get it together! Willem Pieter de Groen says that the harmfulness of corporate tax avoidance and evasion will create a sense of urgency for Europe to move towards a consolidated corporate tax Improving the international tax system Pascal Saint-Amans and Grace Perez-Navarro outline how the OECD is committed to ensuring that the outdated international rules are revamped to deal with changing business models and the rapidly changing economic environment Why tax corporations at all? Corporation tax is an invisible tax on everyone, making us worse off through lower wages in the short term and worse off through lower investment and output per capita in the long run, writes Ben Southwood
International tax regulation - getting the balance right Christian Kaeser writes that a dispute resolution mechanism which ensures that it is neither the taxpayer who defines the ‘fair share’ of tax nor two or more countries, all with deviating results, that will produce a fair balance Putting fairness at the heart of our tax systems Taxation has never been a word that strikes joy into the hearts of our citizens. But if it can be shown that it is fair and effective it will at least gain greater popular acceptance, Algirdas Šemeta writes Base Erosion and Profit Shifting - business support for collaborative solutions International tax rules have not kept pace with globalisation and the BEPS Action Plan seeks to remedy this, writes Will Morris Radical change on the way for Dutch royalty conduits Newly introduced Dutch ‘substance’ requirements and an agreed change to the EU Royalty and Interest Directive may bring radical change to the way Dutch royalty conduits will operate in future, writes Jos Peters What does the future hold for the Dutch royalty conduit companies? Reorganising Dutch royalty conduit structures, due to several new rules and regulations that will enter into force in 2014, seems unavoidable, writes Jos Peters Base erosion and profit shifting — what the BEPS does it mean? Catherine Schultz says that the Obama Administration is very supportive of the BEPS project, but does not have tax reform as a high priority The OECD report on BEPS concerning the perceived abuse of commissionaire structures Commissionaire structures are to be brought under the working of the permanent establishment article of tax treaties writes Jos Peters The Netherlands: a favourable jurisdiction for intermediate holding companies Jos Peters discusses how companies can receive a Dutch tax credit for foreign dividend withholding tax FATCA – business support for a global solution The Foreign Account Tax Compliance Act presents business with unique challenges and an opportunity to find global solutions to a single country’s broadly-applicable tax legislation, Keith Lawson writes Spain: the challenge to set an effective tax policy Rafael Fuster says that Spain faces significant economic and social challenges as a result of the crisis The impact of Financial Transaction Tax (FTT) on financial stability Emrah Arbak argues that the FTT fails to address the key factors that contributed to he global financial crisis The mini-One Stop Shop for VAT - the start of something big! Algirdas Šemeta writes that the strength of the single market, and the ease with which businesses can operate cross-border, are among the key determinants in how quickly the EU will return to economic growth Tax avoidance in Europe Federico Cincotta asks where should the line be drawn between legitimate financial planning and 'abusive' arrangements? The dangers of the new functional risk analysis This new analysis can lead to the application of entirely subjective standards and create additional uncertainty for taxpayers, write Andrew W Steigleder, David F Abbott, and Brian W Kittle Why should business be interested in tax and development? Pascal Saint-Amans says that investors have a clear interest in helping build the capacity of tax administrations in the developing world Tax risk management, corporate governance and the enhanced relationship Tax administrations are stepping up their enforcement efforts writes Grace Perez-Navarro Base erosion and profit shifting In the aftermath of the biggest financial crisis of our lifetime, fiscal consolidation has become an inescapable reality as many governments seek to rebuild solid foundations for growth, Masatsugu Asakawa writes OECD launches its Global Forum on VAT Piet Battiau discusses the increasing importance of VAT as a source of government revenue Transfer pricing and the arm’s length principle The growth of international commerce has led more and more countries to have an active interest in transfer pricing, Joseph Andrus points out The OECD discussion draft on the definition of permanent establishment Jacques Sasseville looks at the concept of permanent establishment, which is the keystone of the existing tax treaty rules that govern the allocation of taxing rights over the business profits that foreign enterprises derive from a country OECD work on the resolution of international tax disputes Marlies de Ruiter and Edward Barret discuss Article 25 (Mutual Agreement Procedure) of the OECD Model, which provides a mechanism for the resolution of international tax disputes Global Forum: real change towards international tax cooperation In times of growing economic uncertainty, international cooperation in tax matters has become a high priority on governments’ agenda. Monica Bhatia writes about the Global Forum on Transparency and Exchange of Information for Tax Purposes Initiatives in the transfer pricing area Krister Andersson comments on initiatives in the transfer pricing aspects of intangibles International Tax Archive To link to archive articles click here
Tax co-operation: beyond exchange of information on request Achim Pross and Stephanie Smith discuss dramatic improvements in exchange of information on request over the last couple of years.