Company Tax Reform in the European Union

The European Commission recently proposed to move towards a consolidated tax base for European multinational companies, to be allocated across EU member states through a system of formula apportionment. This paper argues that while the Commission's blueprints for company tax reform may reduce existing problems of transfer pricing, they will also create new distortions as long as existing tax rate differentials are maintained. The paper also investigates the changes in international tax spillovers which will occur as a result of a switch from the current system of separate accounting to formula apportionment. The final part of the paper discusses whether more conventional corporate tax harmonization should still be a long term policy goal for the EU and presents quantitative estimates of the efficiency gains from harmonization.     

Tax Competition and Tax Coordination in the European Union

This paper examines the tax competition literature and attempts to draw out its implications for the debate on corporate tax coordination within the EU. It begins with the early basic tax competition model, which derives conditions under which underprovision of public services occurs and tax harmonization unambiguously improves welfare for all states in the union. The paper then turns to a wide variety of extensions of this model, some of which reinforce its results and others that yield rather different conclusions. The analysis concludes by considering the implications of the tax competition literature for the debate on EU corporate tax coordination, drawing on some recent efforts to synthesize this vast literature by estimating the efficiency costs of tax competition and simulating the efficiency gains from various tax coordination palns.     

税制结构演变的国际经验与中国展望

税制结构的演变受到经济因素、政府政策目标、国家和社会关系的影响和约束,具有普遍的规律性。考察世界各国税制结构的演变历程可以发现,发达国家税制结构和税种结构均比较稳定,直接税占比高但税种分散,货物与劳务税仍为最大的单一税种;发展中国家税制结构相对稳定但税种结构呈趋势性变化,个人所得税和企业所得税均稳中有升。个人所得税和社会保障缴款是国家间税制结构差异的主要来源,企业所得税负担的国际竞争面临深刻变化。当前我国已基本形成了双主体税制结构,直接税收入中所得类税收、企业主体税收占比较高。鉴于此,我国应在强化均贫富、促消费的目标下,提高个人所得税比重、完善财产税制度、加强自然人税源管理;在新经济增长模式下,对增值税进行适应性调整和税负优化。     

Prospects for Co-ordination of Corporate Taxation and the Taxation of Interest Income in the EU

This paper evaluates the recent proposals for a co-ordinated capital tax policy in the European Union, focusing on an EU-wide minimum withholding tax on interest income and alternative ways to increase the effective tax rate on corporate profits. The analysis draws on current theoretical and empirical research and views the recent capital tax reforms undertaken by individual member countries as rational adjustments to changing conditions in capital markets. Special emphasis is placed on the constraints for EU tax policy imposed by the possibility of shifting capital income to third countries. The paper concludes that some aggregate efficiency gains can be expected from the EU co-ordination proposals, but additional tax collections will be limited largely to the group of small savers while highly mobile large-scale investors are likely to avoid the EU tax.     

IAS/IFRS in Belgium: Quantitative analysis of the impact on the tax burden of companies

The adoption of International Accounting Standards and the International Financial Reporting Standards (IAS/IFRS) in the European Union is part of the European Commission's global tax harmonisation policy whose aim is to establish a common (consolidated) corporate tax base. The paper shows that the impact of an IAS/IFRS-based tax accounting on the effective tax burden of Belgian companies is large and not uniform across sectors. Some sectors, like construction and automotive vehicles, experience much larger increases in effective tax burdens than others. Globally the impact is relatively important. The analysis is conducted using the European Tax Analyzer (ETA), a multi-period forward looking program. In a European context, an IAS/IFRS-based tax accounting will increase the effective corporate tax burdens in all selected countries. However, it will most probably maintain the current tax competitive positions of EU countries. The expected broadening of the tax base could constitute an opportunity to reduce the corporate income tax rate without changing the overall effective burden.     

Evidence of the effect of domicile on corporate average effective tax rates in the European Union

We estimate (worldwide) corporate average effective tax rates (ETRs) from financial statements for companies domiciled in European Union (EU) member states during 7 years from 1990 to 1996. Our objective is to compare the tax rate effectively experienced by each company with the corporate statutory tax rate (STR) in the EU country in which each company is domiciled. The difference between the corporate statutory tax rate and the financial statement-based corporate average effective tax rate provides information on the magnitude of tax incentives provided by governments within the EU. These tax incentives come on top of the directly observable differences in statutory tax rates between EU member states. We find (1) that the use of tax incentives, over and above differences in STRs, differs substantially between EU member states (corporate domiciles) and (2) that the provision of tax incentives does not have the effect of equalizing corporate ETRs between EU member states (corporate domiciles).     

Corporate tax policy and incorporation in the EU

In Europe, declining corporate tax rates have come along with rising tax-to-GDP ratios. This paper explores to what extent income shifting from the personal to the corporate tax base can explain these diverging developments. We exploit a panel of European data on legal form of business to analyze income shifting via incorporation. The results suggest that the effect is significant and large. It implies that the revenue effects of lower corporate tax rates—possibly induced by tax competition—will partly show up in lower personal tax revenues rather than lower corporate tax revenues. Simulations suggest that between 12% and 21% of corporate tax revenue can be attributed to income shifting. Income shifting is found to have raised the corporate tax-to-GDP ratio by some 0.25% points since the early 1990s. This research was carried out while Ruud de Mooij was a visiting fellow at DG ECFIN in October 2006. The views expressed in this Article are those of the authors and do not necessarily reflect the official position of the European Commission.     

我国宏观税收负担走势分析与政策选择

从大的方面看,世界各国宏观税负水平的差异主要表现为发达国家和发展中国家的税负差异,造成这些差异的主要原因包括经济发展水平、社会保障制度和税收征管水平、税收制度以及优惠政策等。通过对我国目前宏观税负水平的判断,应该在推进税费改革、实现增值税转型、规范企业所得税优惠等方面有所改进。     

一个有远见的税收制度应当关注未来的税基——特朗普新税法的成本分析及政策建议

20世纪50年代以来,美国企业所得税税率持续下降,政府税收收入也处于较低水平。2017年,特朗普新税法的实施大幅度降低了企业所得税税率,导致政府税收损失远超预期。然而,新税法实施后,美国企业投资和长期经济增长并没有明显改善。本文认为,一个国家经济效率主要取决于税基而非税率,美国政府应通过税收制度改革,增加对企业投资和研发投入的激励,从而扩大税基,实现经济的长期改善。     

完善结构性减税政策的着力点与路径选择

根据目前我国所面临的新形势、新任务,完善结构性减税政策的着力点应该放在三个方面:针对特定税种进行有增有减的调整,促进税制结构的优化;针对特定群体实行减税或增税政策,实现税收负担的公平;将结构性减税与经济结构调整对接,助推经济结构的优化。立足于这三大着力点,完善结构性减税政策的基本路径选择为:推进增值税扩围改革;调整消费税;减免部分进口环节税收;实行综合与分类相结合的个人所得税制;进一步完善企业所得税优惠政策;深化个人住房房产税改革;全面推广资源税;研究开征环境保护税等新税种。     

Corporate tax revenues in OECD countries

This paper studies variation among OECD countries in the size of corporate income tax revenues relative to GDP over the time period 1979–2002. A decomposition explains such variation as a function of the statutory tax rate, the breadth of the tax base, corporate profitability, and the share of the corporate sector in GDP. Empirical results indicate a parabolic relationship between tax rates and revenues, implying a revenue-maximizing corporate income tax rate of 33% for the whole sample. This revenue-maximizing rate is found to decrease as economies are smaller and more integrated with the world economy. JEL Classification H25, H87     

Should Firms Going Public Enjoy Tax Benefits? An Analysis of the Italian Experience in the 1990s

In Italy tax benefits are granted to firms going public. However, does such tax relief really reduce the corporate tax burden? In this study we tackle the issue by considering 21 industrial firms that were listed on the Italian Exchange from 1995 to 1997 and enjoyed a temporary tax rate cut‐off. We find that the increase in the taxable income reported by these firms largely counterbalances the effect of the tax relief. We conclude that a tax rate cut‐off may not necessarily provoke a reduction in the tax burden for newly listed firms, since in the short term they report larger earnings compared with privately‐owned companies. We claim that this ‘induced’ effect is mainly due to: the significant improvement of operating performance in the year of the listing; the reduction of the debt tax shield; an increase in investment and more accounting transparency. Our findings suggest that tax relief for IPO firms does not necessarily mean a loss of revenue for the government.     

加拿大公司所得税制度与征管经验借鉴

加拿大的公司所得税制度体系完备,征管体系也较为合理,促进了经济的持续稳定发展。本文详细介绍了加拿大公司所得税制度及其征管体系,并提出我国在完善企业所得税制度时应借鉴其对公平与效率的兼顾以及加强税收征管的一些有效经验。     

企业集团合并纳税：比较及启示

我国的合并纳税制度目前只针对特批企业,这不利于企业集团之间公平竞争。对企业集团合并纳税范围及不同国家合并纳税模式的比较与分析表明:我国应进一步完善所得税法等法律法规,保证税收公平,积极建设我国的"集团纳税制度"。     

汽车制造业税负及其影响因素的实证研究——基于上市公司财务数据

以45家汽车制造行业上市公司2010～2011年财务数据为样本,研究发现汽车制造业的流转税税负分别为0.018、0.0075,所得税税负分别为0.1951、0.2079,且所得税税负变化很异常。对税负的影响因素进行实证分析表明:主营业务收入、净资产收益率对流转税税负的影响为正向的,主营业务成本和存货变动率对流转税税负的影响是负向的;资产负债率对所得税税负的影响是负向的,企业的规模、固定资产密度、净资产收益率对所得税税负的影响是正向的。     

美国公司所得税制的实践及其对我国的启示

传统公司课税理论从法人性质角度说明公司负担所得税的合理性,但是这种解释方式受到了现行公司组织形式多样化的挑战。美国之所以对C公司、S公司、有限责任公司和开放式合伙采取灵活多样的所得税制,而不受纳税人是否具有独立法人资格的影响,乃是贯彻应能负税原则使然。在这一理论的指导下,并受国际上减轻经济性双重征税趋势的影响,我国对一人公司应改为采用单一课税模式。     

Why Capital Income Taxes Survive in Open Economies: The Role of Multinational Firms

This paper discusses the role of multinational firms and double taxation treaties for corporate income taxation in open economies. We show that it is optimal for a small open economy to levy positive corporate income taxes if multinational firms are taxed according to the full taxation after deduction system or the foreign tax credit system. Positive corporate taxes also occur in the asymmetric case where some countries apply the exemption system and others apply the tax credit system. If all countries apply the exemption system, the optimal corporate income tax is zero. We also show that, under tax competition, corporate income taxes are not necessarily too low from the perspective of the economy as a whole. While the undertaxation result is confirmed for the case of the exemption system, tax rates may also be inefficiently high if the deduction or the credit systems are applied.     

From the global income tax to the dual income tax: Recent tax reforms in the Nordic countries

The paper discusses the recent drive toward a system of dual income taxation (DIT) in the Nordic countries. The pure version of this system combines progressive taxation of labor and transfer incomes with a proportional tax on income from capital at a level equal to the corporate income tax rate. The paper considers the motives for the introduction of this new income tax system, ranging from abstract theoretical arguments to very pragmatic considerations. While the Nordic DIT system violates the principles of the conventional personal income tax, it is argued that it may in fact be more in line with the philosophy of a true Haig-Simons comprehensive income tax. It is also suggested that the DIT system may cause fewer distortions to resource allocation than the conventional income tax. On the debit side, the paper points out several practical problems of taxing income from small enterprises under the differentiated income tax.     

Corporate Tax Harmonization in Europe: It's All About Compliance

Although the hope may be to reduce economic distortions in captial markets, the primary focus of corporate tax consolidation among member states of a federation is to reduce compliance and administrative burdens. For example, the Canadian provinces have sufficient flexibility to determine their corporate tax policies, and effective tax rates on captial vary considerably by province, but they still have achieved a considerable degree of harmonization of tax bases. The European Union should also try to implement a consolidated tax base for companies. A compulsory base would be best, but it is likely that the optional consolidated tax base is most practical at this time.     

Neutral Taxation of Shareholder Income

A Norwegian tax reform committee recently proposed a personal tax on the realized income from shares after deduction for an imputed risk-free rate of return. This paper describes the design of the proposed shareholder income tax and shows that it will be neutral with respect to investment and financing decisions and decisions to realize capital gains, provided that full loss offsets are granted. Thus the tax allows some non-distortionary double taxation of corporate equity income. With an appropriate choice of tax rates, it also solves the problem of income shifting under a dual income tax. JEL Code: H24, H25