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     

公司所得税改革的世界趋势:价值取向与具体措施

随着经济全球化的发展和国际间资本流动的加速,在追求公平、效率、收入的基础上,世界公司所得税改革的价值取向已进一步提升到提高本国税制竞争力、吸引国际投资的高度,降低税率、扩大税基、消除股息双重征税以及对现金流量税的理论推崇也成为实现这一价值理念的基本措施。     

借鉴国外经验完善我国外国税收抵免制度

本文从消除国际双重征税的方法、外国税收抵免的条件、外国税收抵免的限额等角度对中美外国税收抵免制度进行了详细比较,并指出了我国外国税收抵免制度存在的缺陷,认为应借鉴国外经验对我国的外国税收抵免制度加以完善。     

Do tax sparing agreements contribute to the attraction of FDI in developing countries?

Measuring the effects of taxation on FDI in developing countries requires consideration of the tax sparing provision. This provision signed between developed and developing countries protects host country fiscal incentives for FDI. This paper estimates the impact of tax sparing provisions on Japanese outbound FDI between 1989 and 2000. We find evidence that the tax sparing provision influences positively the location of Japanese FDI, even after having taken into account reversal causality. JEL Classification F23 · H25 · H32 We Thank Michael Devereux, Edward Graham, Robert Lipsey, David Margolis, Claudia Rivas, Deborah Swenson, anonymous referees and seminar participants at the Franco-Korean conference in Seoul, and at the Western Economic Association conference in Vancouver for helpful discussions.     

The roles of book‐tax conformity and tax enforcement in regulating tax reporting behaviour following International Financial Reporting Standards adoption

This study investigates whether increasing the level of tax enforcement can potentially offset the primary cost of a reduction in the level of book‐tax conformity (BTC) following International Financial Reporting Standards (IFRS) adoption – increased tax avoidance. We find that after the decrease in BTC and the concomitant increase in tax enforcement that followed IFRS adoption in Israel, tax avoidance declined significantly. Our results imply that one of the primary costs of reducing BTC can be avoided. Moreover, the results suggest that rather than one strict regulatory approach to deal with reporting manipulations, a combination of trust and control is more effective and less radical.     

An examination of the political salience of corporate tax avoidance: A case study of the Tax Justice Network

Corporate tax avoidance (CTA) has become a high profile issue despite being a complex area of accounting practice. One reason for this has been the civil society campaign opposing tax avoidance. The paper provides a case study of one key civil society actor: the Tax Justice Network (TJN). Existing accounting analysis offers little to explain how some accounting issues acquire political attention and media coverage. To address this, the concept of political salience is introduced into accounting analysis – understood as the creation of focal points in campaigns – to consider how the TJN contributed to the political profile of CTA.     

Determinants of tax haven utilization: evidence from Australian firms

This paper examines the major determinants of tax haven utilization based on a sample of 200 publicly listed Australian firms, over the 2006–2010 period (1,000 firm‐years). Our regression results show that variables relating to transfer pricing, intangible assets, an interaction term between transfer pricing and intangible assets, withholding taxes, performance‐based management remuneration and multinationality are positively associated with tax haven utilization. We also find that corporate governance structures are negatively associated with tax haven utilization. The magnitude and significance of the regression coefficients indicate that transfer pricing, withholding taxes, intangible assets, an interaction term between transfer pricing and intangible assets, corporate governance and multinationality are the most important drivers of tax haven utilization.     

Corporate tax payments under formulary apportionment: Evidence from the financial reports of 50 major U.S. multinational firms

Under a formulary apportionment system of taxing multinational corporate income, U.S. tax liabilities would be based on the product of a multinational firm's worldwide income and the fraction of their real activities that occur in the United States – typically, an average of asset, payroll, and sales shares. This analysis utilizes financial reporting data for 50 large U.S. multinational firms to analyze how tax payments would change under a possible formulary system, updating Shackelford and Slemrod (1998). Our time period is 2005–2007 instead of 1989–1993. We find that tax payments under formulary apportionment would increase modestly overall but by a lower magnitude than found by Shackelford and Slemrod. Given the changes in the international tax environment since the earlier time period, this is a puzzling finding; we speculate regarding possible explanations.     

税收竞争和税收套利对国际税收制度的挑战

当前被动投资的税收竞争、主动投资的税收竞争和税收套利等问题阻碍了单一税收原则和受惠原则的实践运用。本文介绍了税收竞争和税收套利对国际税收制度的挑战,并以OECD成员国的应对为例,阐述了OECD成员国不断与时俱进修订税收法规的历程,试图引起人们关注国际税收制度的完善。     

中国-东盟税收协调问题研究

本文认为,中国—东盟的经济一体化发展虽然尚处于自由贸易区建设的低级阶段,但随着一体化步伐的加快,中国与东盟之间生产要素的流动将日趋频繁,因国内税制的差异而造成的税收障碍也将日益突出。为此,以消除税收障碍为重点的税收协调必不可免。秉承循序渐进的协调原则,东盟各成员国应该规范、完善现行税制,拓宽税收协定网络,加强国际税收合作;而中国则应致力于深化税制改革,完善国际税收制度。     

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.     

Value-added tax options for India

The pressures of aggregate revenue, the requirement of a reduced role for customs duties for the liberalization of the economy, and the complexity and strains of the current system together point clearly toward the desirability of tax reform in India. Since domestic indirect taxes provide the major source of revenue, they deserve special attention. This paper argues that India would benefit from moving toward a system of value-added taxation (VAT) and focuses on the way in which a VAT (or VATs) can be best introduced into India given the country's federal structure. Three different options are distinguished: a central VAT, dual VAT, and states' VAT. We argue that the first is politically infeasible, that the second represents the best way forward in the short term, and that the third deserves consideration as a long-run option. Special attention is paid to the problems that would arise under either a states' or a dual VAT with regard to taxing interstate trade.     

对跨国独立劳务所得认定的探讨

跨国独立劳务所得的认定在理论和实践中存在很多争议。本文结合《联合国税收协定范本》和《OECD税收协定范本》对此问题的不同规定,就我国在具体税收实践中对这一问题应如何认定进行了探讨。     

Does recent empirical evidence support the existence of international corporate tax competition?

Recent reductions in institutional barriers to international investment have meant that the existence of international corporate tax differentials is now one of the most significant remaining causes of distortion to the optimum global allocation of resources, and hence to international trade. In the debate as to how to reduce such distortion, two main schools of thought have emerged. The first believes that this result can be achieved primarily through the international co-ordination of corporate taxes. To date, efforts in this direction have not made significant progress. The second contends that market forces, through tax competition, will spontaneously reduce international corporate tax differentials. In this article, an analysis of recent trends in corporate tax rates supports this second contention: statutory and effective corporate tax rates are continuing to decline and converge. However, recent tax revenue data give little support for the existence of tax competition; the expected shift in the tax burden from corporate profits onto less mobile factors such as labor has largely failed to materialize. Several explanations for these contrasting findings are outlined and analyzed.     

Government ownership,corporate governance and tax aggressiveness: evidence from China

This study investigates how government ownership and corporate governance influence a firm's tax aggressiveness. Using Chinese listed companies during 2003–2009, we find that compared with government‐controlled firms, non‐government‐controlled firms pursue a more aggressive tax strategy. In particular, non‐government‐controlled firms with a higher percentage of the board shareholdings and with a CEO who also serves as the board chairman are more aggressive. For government‐controlled firms, we find that board shareholding has an impact on tax aggressiveness and it does not differ between local and central government‐controlled firms. However, local government‐controlled firms in less developed regions where the implementation of corporate governance measures is generally less effective are more tax aggressive than those in other regions.     

VAT attacks!

Like the theory of the second best that the 2006 congress marks, the value added tax (VAT) is now fifty years old. Judged by the extent and speed of its spread around the world, and the revenue that it raises, the VAT would seem to have been a remarkable success. Over the last few years, however, it has come under a series of attacks. This paper considers three of the most prominent of these. One is the fear (raised mainly in the United States) that the VAT actually does too good a job of raising tax revenue—which raises the empirical question of whether it has indeed proved as effective a source of revenue as its proponents claim and its opponents fear. The second is the view that the VAT does a bad job of taxing the informal sector—and that tariffs might consequently be a better revenue-raising instrument for many developing countries. The third attack is the most literal, by criminals rather than theorists: in the European Union and elsewhere, sophisticated VAT fraud, targeting its refund provisions, has become a serious concern. The paper also argues, more generally, that the many unanswered questions concerning the VAT reflect an unfortunate disconnect between the development of the tax itself and of second best tax analysis. I am grateful to Ben Lockwood and Stephen Smith for allowing me to draw on our joint work, and to Vidar Christiansen, Sijbren Cnossen, Isaias Coelho, Alain Jousten, Victoria Perry, and Emil Sunley for many helpful comments and suggestions. Views and errors remain mine alone, and should not be attributed to the International Monetary Fund.     

The intoxicating brew of black liquor and son of black liquor: Deciphering the tax planning,research, policy and financial statement implications of tax credits via financial reporting income tax disclosures

In 2007, a change in the law regarding the alternative fuel mixture credit opened the door for paper mills to qualify a byproduct of paper manufacturing, black liquor, as a fuel eligible for the credit. The credit is a refundable credit of $0.50 per gallon. Paper mills can produce hundreds of millions of gallons of black liquor per year and qualified for the credit in 2009. In addition, in 2010 the IRS determined that these firms qualified for the cellulosic biofuels producer credit. Paper mill companies could amend their 2009 tax returns and swap their alternative fuel mixture credits for cellulosic biofuels producer credits worth $1.01 per gallon. The catch was that the alternative fuels mixture credit was refundable; the cellulosic biofuels producer credit was nonrefundable.     

国际视角下中国环境税研究

目前,环境税体系在欧盟国家已经相对成熟,中国的环境税的开征方案也正在制定过程中。本文厘清了国际上不同口径的环境税定义,并分析了环境税的经济效应,最后,阐述了中国开征环境税的必要性及改革思路。     

Determinants of the variability in corporate effective tax rates and tax reform: Evidence from Australia

This study examines the determinants of the variability in corporate effective tax rates in Australia spanning the Ralph Review of Business Taxation reform. Our results indicate that corporate effective tax rates are associated with several major firm-specific characteristics, including firm size, capital structure (leverage) and asset mix (capital intensity, inventory intensity and R&D intensity). While the Ralph Review tax reform had a significant impact on many of these associations, corporate effective tax rates continue to be associated with firm size, capital structure and asset mix after the tax reform.     

Shareholder taxation and aggregate dividend payout: Evidence from the tax reform act of 1986

The effect of shareholder taxation on corporate dividend policy is a major controversy in financial economics. The Tax Reform Act of 1986 eliminated the statutory tax disadvantage of dividends versus long-term capital gains for individual shareholders. Using aggregate time series data I find evidence that corporate dividend payout has become more generous in the period after tax reform.