Corporate income taxation in Lithuania in the context of the EU

This paper explores Lithuania's competitiveness in the area of corporate income taxation. In order to assess how much freedom of action the country has in designing its own corporate income tax policy, the process of EU tax harmonization is analyzed by evaluating justification for tax harmonization, the major developments and the main outcomes of this process. Lithuania's corporate income tax system is compared with the systems in the other EU countries. Following a macro backward-looking approach, the paper calculates the measures of effective profit tax burden. Effective tax burden measures are computed for the whole enlarged EU. Such calculations are still rare in the economic literature.     

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"。     

Bilateral effective tax rates and foreign direct investment

This paper computes effective (marginal and average) tax rates that account for bilateral aspects of taxation and, therefore, vary across country-pairs and years. These tax rates serve to estimate the impact of corporate taxation on outbound stocks of bilateral foreign direct investment (FDI) among OECD countries between 1991 and 2002. The findings indicate that outbound FDI is positively related to the parent and host country tax burden and negatively associated with bilateral effective tax rates. Relying only on unilateral (country and time variant) rather than on both unilateral and bilateral (country-pair and time variant) effective tax rates leads to biased estimates of the impact of corporate taxation on FDI.     

Firm-specific forward-looking effective tax rates

This paper computes effective (marginal and average) tax rates that account for bilateral aspects of taxation and, therefore, vary across country-pairs and years. These tax rates serve to estimate the impact of corporate taxation on outbound stocks of bilateral foreign direct investment (FDI) among OECD countries between 1991 and 2002. The findings indicate that outbound FDI is positively related to the parent and host country tax burden and negatively associated with bilateral effective tax rates. Relying only on unilateral (country and time variant) rather than on both unilateral and bilateral (country-pair and time variant) effective tax rates leads to biased estimates of the impact of corporate taxation on FDI.     

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.     

How Much Do Taxes Discourage Incorporation?

The double taxation of corporate income should discourage firms from incorporating. We investigate the extent to which the aggregate allocation of assets and taxable income in the United States between corporate and noncorporate firms responds to the size of this tax distortion during the period 1959–1986. In theory, profitable firms should shift out of the corporate sector when the tax distortion is large, and conversely for firms with tax losses. Our empirical results provide strong support for these forecasts, and imply that the resulting excess burden equals 16 percent of business tax revenue.     

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。     

Theft and taxes

This paper analyzes the interaction between corporate taxes and corporate governance. We show that the design of the corporate tax system affects the amount of private benefits extracted by company insiders and that the quality of the corporate governance system affects the sensitivity of tax revenues to tax changes. Analyses of a tax enforcement crackdown in Russia and cross-country data on tax changes support this two-way interaction between corporate governance and corporate taxation.     

“营改增”能否促进企业价值提升

"营改增"通过打通增值税抵扣链条、消除重复征税等,对企业税负降低和专业化分工会产生一定的促进作用,进而能够显著提升企业价值。而交通运输业由于"营改增"前后适用税率差异较大,且固定资产更新周期较长带来的进项抵扣不足,使得"营改增"对其企业价值的影响程度反而不及现代服务业。与私营企业相比,国有企业更容易受到政府政策干预或扶持,对税收政策的敏感性不及私营企业,即"营改增"对私营企业的企业价值的影响程度显著高于国有企业。鉴于"营改增"对企业价值的促进作用,国家应继续优化增值税体系,保持税收政策在促进企业价值提升时政策红利的延续性;在推行增值税改革的过程中,要增加配套税收优惠政策,以弥补政策效应对某些行业激励不足的短板;此外,要加快国有企业改革,营造公平的营商环境,促进税收中性原则的有效发挥。     

European tax systems and the neutrality of corporate financing policy

The different tax systems of European illustrate the variety of ways in which the double taxation of dividends can be reduced. This paper analyses the effect of corporate financing policy under the imputation, dual rate, mixed and classical tax systems, and derives conditions for neutrality of the systems with respect to financing policy-neutrality in the sense that no type of financial policy has favourable tax treatment. The effect of the capital gains tax and heterogenous personal tax rates across individuals are analysed by using a model of stock value. Neutrality depend on the parameters of the tax system and a weighted average of personal tax rates.     

Determinants of Bilateral Effective Tax Rates: Empirical Evidence from OECD Countries*

This paper identifies the relevant determinants of a company's effective tax burden. Thereby, we account for bilateral aspects of corporate taxation by calculating bilateral effective tax rates as proposed by Devereux and Griffith (1999 and 2003). The empirical evidence of a large panel of nearly 8,000 bilateral effective tax rates within the OECD suggests that country size is an important determinant of the effective tax rate. In line with the literature, bilateral tax rates with small host countries exhibit a smaller overall effective tax rate, despite the fact that larger countries are more likely to reduce the tax burden by means of tax treaties at the bilateral level. Further, we find that geographically remote countries impose higher taxes, whereas economic integration tends to reduce the extent of the bilateral effective tax burden.     

税收效率思想发展演进及其前沿研究

税收效率研究的理论前提是经济效率的实现,亚当·斯密最早系统地阐述了税收效率思想,以后的西方学者分别从税收经济效率、税收超税负担、税收征管效率以及税收制度效率等方面对税收效率进行了研究.西方税收效率演进过程启示我们,对税收效率的研究不能仅局于经济层面,特别是在经济转型期,面对各种社会矛盾的出现,税收制度在平衡各种社会矛盾和利益冲突方面应该发挥其重要作用.要建立公平优先、兼顾效率的税收理念,通过深化税制改革,实现社会经济的可持续发展.     

优化我国劳务所得课税 促进居民收入分配公平

目前,我国对劳务所得的课税项目分散、同类所得税负不同、税负普遍较重,已构成我国收入分配差距过大的诱因之一。基于此,本文借鉴西方发达国家对劳务课税的先进经验,从课税范围、费用扣除标准和税率设计等方面提出了完善我国劳务所得税制设计的政策建议。     

Bank profitability and taxation

This paper investigates how banks’ activity is affected by the corporate income tax. For this purpose it uses aggregate data on all main components of the profit and loss account and on the interest rate applied on loans and on deposits for the banking sector of the main industrialized countries during the period 1981–2003. With such information we are able to disentangle the extent to which a bank is able to shift its tax-burden forward to its borrowers, depositors, and purchasers of fee-generating services. The main result is that the taxation of banks’ profit is equivalent to a taxation on loans and as such it exerts a substantial impact on the composition of banking sector revenues. However credit intermediaries have the ability to shift a substantial part of their corporate income tax burden and therefore differences in the level of taxation cannot explain the dispersion observed in banks’ net profitability across industrialized countries.     

An empirical study of the impact of corporate taxation on the global allocation of foreign direct investment: a broad tax attractiveness index approach

The question of whether a country’s corporate tax regime has a significant influence on the level of foreign direct investment (FDI) into that country is an important consideration in the design of national tax policy. This is especially relevant today in view of the recent increase in the global mobility of capital and subsequent increase in the importance of FDI to nations’ economies. Although several prior quantitative studies have investigated the link between taxation and FDI, they have tended to be restricted in geographical scope and in their measure of taxation.This study constructs indices of “corporate tax attractiveness” for selected countries and then analyses the relationship between the indices and measures of the flow of FDI into those countries. The indices are constructed by obtaining evaluations from international investors and taxation experts on the various attributes of the tax systems of those selected countries. A significant positive relationship was found to exist between the indices and measures of FDI inflows, and between individual tax system attributes and those inflows, thus adding support to the supposition that host country corporate taxation influences the size of FDI inflows.     

Effects of Capital Gains Taxation on Life-Cycle Investment and Portfolio Management

We examine the impact of capital income taxation, both accrual forms of taxation and taxation of realized capital gains, on total savings and the demand for corporate financial instruments. We find that investors may hold both debt and equity in the face of effective collection of capital gains taxation even in a flat tax system. We also find that the two taxes will have substantially different effects on saving and consumption behavior, making it unlikely that the tax structure can be summarized by any single equivalent accrual tax rate.     

税费替代:增值税减税、非税收入征管与企业投资

通过减税促进企业投资和提振宏观经济是近年来中国税收制度改革的重要目标,但减税政策的实际效果却存在争议。本文利用2009年增值税转型改革,研究了减税对地方政府税费收入和企业非税负担的影响,从税费替代的角度揭示非税负担变动如何影响企业固定资产投资。研究发现:(1)增值税转型在减税的同时提高了地方政府非税收入并加重了企业非税负担,地方财政收入受增值税转型冲击越大,企业非税负担上升越明显。(2)上述应主要体现在小型、微型和民营企业上,大中型、非民营企业的非税负担未发生明显变化。(3)非税负担上升会显著抑制小型、微型和民营企业的固定资产投资,促使小型微型和民营企业通过持有更多现金和减少流动性负债来应对税费负担不确定性。本文有助于理解减税政策对小型微型和民营企业非税负担的溢出效应及其影响,为通过减税降费促进投资和提振经济提供经验支撑。     

Dividend Imputation Systems in Industrialized Countries: An Examination of Relative Tax Burdens

Dividend taxation has been a controversial issue especially since the enactment of the 2003 U.S. legislation entitled “Jobs and Growth Tax Relief Reconciliation Act” (JGTRRA). This paper presents taxonomy of dividend tax systems and illustrates dividend relief practices in the OECD (Organization for Economic Cooperation and Development) countries. None of the OECD countries follow the conduit (i.e., full imputation) system, and the classical system (where double taxation of dividends occurs) prevailed only in one country (Ireland) other than U.S. in 2003. Dividend imputation in most of the OECD countries is only partial and takes place at the shareholder level in the form of tax credit or split rate. The paper also demonstrates a method to compute the effective tax rates (corporate plus individual taxes) on dividends, and presents such rates for the OECD countries. In comparison with the average dividends tax rate of 39.6% in other OECD countries, the U.S. had a rate of 60.7%, which JGTRRA has brought down to 44.8%.     

Statement of the Financial Economists Roundtable: Corporate Tax Reform

Corporate tax reform has been a controversial issue in the U.S. for several years, particularly as U.S. companies have accumulated cash in lower‐tax overseas subsidiaries, while some have used “inversions” to establish overseas corporate domiciles. Two features of U.S. corporate taxation stand out: 1. U.S. corporate income tax rates are the highest in the industrialized world. The federal rate is 35%; and, when combined with state taxes, it averages 39%, as compared to an OECD average of 24%. 2. U.S. corporations pay U.S. tax on their worldwide income, but can choose to avoid indefinitely corporate tax on foreign profits by not repatriating them. Neither feature is present in most other Western countries, where the norm is a “territorial” system that taxes companies only on their domestic profits. The Trump administration has proposed to cut U.S. corporate tax rates to 20%, thereby bringing them down to the OECD average, and to adopt a territorial tax regime like those found in most other Western nations. In this statement signed by 31 senior financial economists, the authors recommend cutting U.S. corporate tax rates, but retaining the current system of taxing the worldwide profits of U.S. companies (while giving them credit for taxes paid in overseas jurisdictions). Once U.S. rates drop to the international average, the economists point out, U.S. companies would have much less incentive under the worldwide system to use transfer pricing schemes to shift their profits to low‐tax jurisdictions than under the proposed territorial alternative. Indeed, under the current system, if the lower rates under consideration are enacted, the location of a company's business activity (including the firm's underlying intellectual property) would not affect its taxation. Along with lower corporate tax rates, the economists also recommend that Congress limit or remove the corporate option to defer the taxation of offshore profits and provide a schedule for repatriating off‐shore funds, using the inducement of the now lower rates as well as the possibility of a “tax holiday.”     

Taxation and skills investment in frictional labor markets

This paper examines the effects of wage taxation and corporate income taxation on training investment in frictional labor markets. Because of labor market frictions, the wage structure is compressed and workers do not capture the entire return from their skills. As a result, both firms and workers have incentives to support part of the costs of training investments. The analysis shows that when decisions to invest in training are made by firms and workers acting cooperatively, a wage tax increases the level of investment in skills whereas a corporate income tax decreases it. In this case, the introduction of a small wage tax unambiguously increases efficiency. The effects of both types of taxes on training are reversed when investment decisions are taken by firms alone. In any case, a corporate income tax is not neutral with respect to decisions to invest in skills even if the full cost of investment is deducted from taxable income in the period when it is incurred and the tax system provides full loss offset.