Withholding taxes or information exchange: the taxation of international interest flows

This paper considers withholding taxes and information exchange as alternative means to tax international interest income. For each regime, we consider the maximum level of taxation of foreign-source income that can be sustained as the equilibrium of a repeated game. The best regime is the one that brings the level of taxation in the repeated game closest to the cooperative level of interest taxation. Sustainable levels of taxation in either regime depend on the importance of bank profits and on the marginal cost of public funds, among other things. Simulations with the model illustrate the choice between withholding taxes and information exchange. An explicit possibility is the emergence of a mixed regime, with one country imposing a withholding tax and the other country providing information. The basic model is extended to allow for size differences between the two countries and to incorporate a third, outside country.     

Regional Integration and the Co-ordination of Capital Income Taxation

This paper addresses the question of the need for income tax harmonization in the context of regional integration. It analyses the international distortions and fiscal interdependence arising in the presence of tax rate differentials both under a theoretical and an empirical perspective, and with reference to actual experiences of harmonization attempts. Attention is also paid to the influence of the countries' size on the results, to the strategic behaviour of countries under different international taxations rules, and to the relationships with the countries excluded by the integration process. International tax uniformity does not appear to be the preferable solution, even if some form of concerted agreements might help in reducing inefficiencies deriving from taxation differentials. For instance, in the case of highly mobile factors, like financial capital, if the integrating countries apply the source principle and the interest rate is the same across them, the source-based tax rate on non residents must equal the residence country tax rate on residents. Such a rule would allow the countries to set autonomously their tax rate and, at the same time, eliminate cross-border effects. If there are more than two integrating countries, the tax rates on non residents should discriminate according to the internal tax rate of the residence country.
(J.E.L.: H87, F20, H20).     

PROGRESSIVITY AND REDISTRIBUTION IN NON‐REVENUE NEUTRAL TAX REFORMS: THE LEVEL AND DISTANCE EFFECTS

Kakwani and Reynolds–Smolensky indices are used in the literature to measure the progressivity and redistributive capacity of taxes. These indices may, however, show some limits when used to make normative assessments about non‐revenue neutral tax reforms. Two approaches have traditionally been taken to overcome this problem. The first of these consists of comparing after‐tax income distributions through generalized Lorenz (concentration) curves. The second approach is based on the decomposition of changes in the Reynolds–Smolensky index into changes in the average tax rate and variations in progressivity. Nonetheless, this decomposition between the average tax rate and progressivity may be further exploited to obtain some information that can be relevant to assess tax reforms. The main aim of this study is to draw up some indicators that can be useful to quantify the effects of non‐revenue neutral tax reforms. These indicators are used to investigate the last personal income tax reforms that have taken place in Spain.     

跨国电子商务对国际税收管辖权的挑战及应对策略

跨国电子商务给国际贸易带来便利的同时,也对国际税收管辖权带来挑战,使传统居民税收管辖权、收入来源地税收管辖权的执行遇到困难,且便利国际避税行为、严重影响一国经济利益。面对跨国电子商务带来的挑战,国际社会提出不少观点与解决方案,然而都存在缺陷,不能很好解决跨国电子商务带来的问题。解决跨国电子商务下的税收管辖权问题,要强化跨国电子商务税收征管,以＂比特税＂形式对电子商务关税及其它流转税征收,厘清税收管辖权等。     

Fiscal federalism approach for controlling global environmental pollution

This paper finds that optimal international carbon taxes are country specific and we can decompose a tax on a domestically produced carbon-intensive commodity into a revenue tax, a tax to control local atmospheric pollution and an international carbon tax. It shows that an institutional arrangement for the world economy similar to the fiscal federalism in the federal countries can be useful to internalize the global externalities of atmospheric pollution.     

What Drives Corporate Tax Rates Down? A Reassessment of Globalization,Tax Competition,and Dynamic Adjustment to Shocks*

We reassess the driving forces behind the recent decline of corporate tax rates in Europe. Using data for up to 32 countries from 1983 to 2006, we analyze the roles of economic and financial openness as well as tax competition, while allowing for dynamic adjustment to shocks and period‐specific and country‐specific effects. While there is no evidence that countries that have become more open have reduced their tax rates more, our findings suggest that countries strongly compete over statutory tax rates. A simulation of tax rates in a scenario with no cross‐sectional dependence in tax setting suggests that, in the absence of tax competition, the mean statutory tax rate of Western European countries in 2006 would have been about 12.5 percentage points above its actual level. We conclude that the recent downward trend in corporate taxes is mainly a result of tax competition.     

The Dilemmas of Tax Coordination in the Enlarged European Union

This study evaluates the economic effects of corporate tax coordinationin the enlarged European Union (EU) using a computable generalequilibrium model. Our main findings are as follows: (i) Corporatetax coordination can yield modest aggregate welfare gains. The2004 enlargement of the EU has increased the potential gainsfrom tax harmonization, provided corporate tax rates and taxbases are harmonized at their unweighted averages. (ii) Allscenarios for coordination leave some EU Member States as winnersand others as losers. An agreement on tax coordination is thereforelikely to require elaborate compensation mechanisms. (iii) Thelarge and diverse country effects suggest that Enhanced Cooperationfor a subset of the Member States may be the most likely routetowards tax coordination. (iv) Identifying winners and losersfrom coordination for the purpose of a compensation mechanismmay be problematic, since countries experiencing gains in GDPand welfare tend to lose tax revenues, and vice versa. (JELcodes: H25, H73, H87)     

Growth‐Friendly Tax Structures: An Indicator‐Based Approach

This paper designs a horizontal indicator‐based assessment methodology aimed at identifying those EU countries presenting a potential need and scope for shifting taxation away from labour to other tax bases less detrimental to growth. The assessment methodology, as a first step, selects a set of indicators measuring specific aspects of tax policy. Subsequently, for each individual indicator, performance thresholds are calculated based on a benchmarking approach. Finally, a screening algorithm based on commonly accepted findings from the relevant economic literature is used to assess the overall performance of a country in two policy areas, namely the need for a tax shift and the scope for it. Various robustness checks are performed.     

Competing for a duopoly: international trade and tax competition

Abstract We analyse the tax/subsidy competition between two potential host governments to attract the plants of firms in a duopolistic industry. While competition between identical countries for a monopolist's investment is known to result in subsidy inflation, two firms can be taxed in equilibrium with the host countries appropriating the entire social surplus generated within the industry, despite explicit non‐cooperation between governments. Trade costs mean that the firms prefer dispersed to co‐located production, creating these taxation opportunities for the host countries. We determine the country‐size asymmetry that changes the nature of the equilibrium, inducing concentration of production in the larger country.     

Does eliminating international profit shifting increase tax revenue in high-tax countries?

We analyze under what conditions initiatives intended to eliminate profit shifting (such as the OECD BEPS action plan and the more recent European implementation of the ATAD) can be successful, given that these actions may induce multinational companies to relocate activities to low-tax countries. We demonstrate that removing tax-motivated profit shifting increases tax revenue in the onshore region if the low-tax jurisdiction is not too efficient in providing attractive infrastructure. This outcome is more easily achieved when the high-tax country is able to counter the shifting of international activity using infrastructure investment to compete with the tax haven rather than being passive. International regulations aimed at combating aggressive tax avoidance should anticipate the adverse effects induced by the resulting emergence of other forms of base erosion.     

离岸金融税收征管法制及其在中国的构建

离岸金融税收征管法制主要涉及税收征管原则、国际避税和税收管辖权冲突等问题。实行优惠税制,是全球各离岸金融市场所在国在税收征管方面奉行的一项普遍原则,但各离岸金融中心在税收优惠程度上存在差异。在构建中国离岸金融税收征管法制的过程中,中国在税收征管原则上可以采取中等程度的税收优惠政策,在避税问题上也应采取适中的容忍态度并可以尝试通过预约定价（APA）机制来调整关联企业在离岸市场上的转移定价行为,在离岸金融税收管辖权冲突的解决上应积极参与国际协调。     

Are corporate tax rates, or countries, converging?

The statutory rate and effective tax rate imposed on corporation income—as well as the dispersion of these rates—began to decline in the 1980s. Is this due to changes in the domestic determinants of corporate taxation or increases in international pressures for tax competition?This paper finds clear evidence that the corporate tax rate is insulated from a country's revenue needs: across countries, there is no association of the expenditure-GDP ratio with the corporate statutory rate and only weak evidence of a positive association with the average rate. There is suggestive, but not definitive, evidence that the domestic role of the corporate tax as a backstop to the individual income tax is important: across countries, there is indeed a strong association between the top individual rate and the top statutory corporate rate.There is intriguing evidence about the role of international competitive pressures on corporate taxation. Measures of openness are negatively associated with statutory corporate rates, although not with revenues collected as a fraction of GDP. Strikingly, larger, more trade-intensive countries do collect more corporate tax, but this may be because these countries are more attractive venues for investment.     

Fiscal Equalization and Tax Enforcement

In many countries organized as federations, fiscal equalization schemes have been implemented to mitigate vertical or horizontal imbalances. Such schemes usually imply that the member states of the federation can only partly internalize (marginal) tax revenue before redistribution. Aside from the internalized marginal revenue, referred to as the marginal tax‐back rate, the remainder is redistributed. We investigate the extent to which state‐level authorities in such federation under‐exploit their tax bases. By means of a stylized model, we show that the member states have an incentive to align the effective tax rates on their residents with the level of the marginal tax‐back rate. We empirically test the model using state‐level and micro‐level taxpayer data, OLS regressions and natural experiments. Our empirical findings support the results from our theoretical model. Particularly, we find that states with a higher marginal tax‐back rate exploit the tax base to a higher extent.     

Strategic Environmental Policies when Waste Products are Tradable

The paper deals with international trade in hazardous waste products when there is an international oligopoly market for waste, and both waste‐importing and waste‐exporting countries act strategically to utilize national environmental policies to attach rents arising from trade in waste. The authors model a multiple‐stage game where waste is generated in an industrialized country as a byproduct of production, and potentially is exported to some less‐developed countries, if not abated locally, or imposed on local residents at a cost of an environmental tax. In the market for waste, an oligopolistic supply is assumed. The demand for waste is perfectly competitive, with waste‐processing firms guided by marginal disposal costs and environmental taxes levied by foreign countries. With each country playing Nash, the analysis finds domestic and foreign taxes to be distorted from the Pigouvian taxes in such a way that the domestic (waste‐exporter) tax rate is set below, and the foreign tax rate is set above, the Pigouvian taxes. However, a global welfare optimum requires tax distortions in the opposite direction, in the sense that foreign environmental taxes must be set below the Pigouvian tax rate.     

Behavioral Effects of Withholding Taxes on Labor Supply*

In most advanced economies, income tax collection uses third‐party withholding for wage income. Because withholding taxes do not necessarily reflect true effective taxes, these may give false signals of net‐of‐tax pay. We test labor supply responses to such misconceptions using laboratory experiments. Withholding taxes (and the resulting tax refunds) should be behaviorally neutral, but our results show that tax adjustments lead to effort adjustments, which suggests that withholding blurs tax incentives. While there is no statistically significant response in the overall sample, the participants in the subgroup who self‐assess to be motivated by monetary incentives (about half of the total sample) reduce their effort in response to withholding taxes and increase their effort after receiving tax refunds.     

The Feasibility of the Double‐Dividend Hypothesis in a Democratic Economy

The two dividends in the double‐dividend hypothesis are assumed to be independent. This assumption can be misleading when it comes to formulating policy. I construct a model where the pollution tax rate is voted for by heterogeneous people. In addition to the revenue‐recycling effect, the equilibrium pollution tax rate depends on two opposite forces: the tax‐cutting effect and the profit effect. The two forces show that an instrument that exploits a greater revenue‐recycling effect can cause a more severe environmental deterioration, thereby resulting in the infeasibility of the hypothesis. The introduction of the interdependence between the two dividends can also mean that non‐revenue‐raising instruments are more efficient than revenue‐raising instruments.     

Tax Reform,Delocation, and Heterogeneous Firms*

The standard international tax model is extended to allow for heterogeneous firms when agglomeration forces are important, enabling us to study the relocation effects of taxes that vary according to firm size. We show that allowing for heterogeneity permits a given tax scheme to have an endogenously different effect on the location decision of small and big firms, with the biggest firms being endogenously more likely to relocate in reaction to high taxes. We show that a reform that flattens the tax–firm–size profile can raise tax revenue without inducing any relocation.     

Corporate Tax Reductions,Cross‐Border Ownership and Welfare

In this paper, a three‐country model incorporating the cross‐border ownership of stock and international firm relocation is constructed. Using this model, the effects of a reduction in the corporate tax on welfare in all three countries is examined. The findings indicate that if the country undertaking the reduction is moderately rich, and one of the two remaining countries is rich while the other country is poor, the tax reduction not only brings about a positive effect on its own welfare, but also increases the welfare of the rich foreign country and lowers that of the poor foreign country.     

Addiction to debt forgiveness in developing countries: Consequences and who gets picked?

We explore whether the expectation of debt forgiveness discourages developing countries from attaining sustainable fiscal independence through improving their tax effort. While the international financial community advises poor countries to improve revenue mobilization, the same international community routinely bails out poor countries that fail to meet their loan repayment obligations, among other reasons as a result of the low tax effort they exercise. The act of bailing out creates an expectation about receiving debt forgiveness time and again in the future. The key prediction of our theoretical framework is that in the presence of debt forgiveness, countries’ tax efforts will decline and more so the higher the intensity of the bailouts. We test this proposition using data for 55 countries from 1995 to 2015. We find that debt forgiveness is significant in lowering tax effort. In addressing the potential of reverse causality, we also find that the international financial community has been more forgiving to countries that exert lower tax effort. These results, which are robust to various specifications, have significant policy implications for donor and recipient countries.     

Company taxation and tax spillovers: Separate accounting versus formula apportionment

It is observed in the real world that taxes matter for location decisions and that multinationals shift profits by transfer pricing. The US and Canada use so-called formula apportionment (FA) to tax corporate income, and the EU is debating a switch from separate accounting (SA) to FA. This paper develops a theoretical model that compares basic properties of FA to SA. The focal point of the analysis is how changes in tax rates affect capital formation, input choice, and transfer pricing, as well as on spillovers on tax revenue in other countries. The analysis shows that a move from SA to FA will not eliminate such spillovers and will, in cases identified in the paper, actually aggravate them.