Free trade taxation and protectionist taxation

The goal of this paper is to seek new insight regarding international tax policy by recasting it in parallel with the theory of international trade. This is accomplished by defining a free trade taxation regime as one that is consistent with an efficient worldwide allocation of capital, and evaluating within this perspective various aspects of tax policy, such as value-added (axes, integration, income shifting, and the choice of worldwide or territorial system of taxes.Compatibility with free trade is not the only standard against which to judge an international tax system. Nevertheless, as national economies become more integrated the importance of international taxation for the efficient functioning of capital markets will become a central policy issue.     

Agency and Tax Explanations of Security Issuance Decisions

This paper is an empirical examination of the relative roles of agency and tax considerations in corporate debt versus equity issuance decisions. Unlike earlier work, we conduct our tests on a sample of UK firms since the UK system of taxation does not create an obvious tax advantage to debt and hence affords an opportunity to evaluate the relevance of tax arbitrage considerations. We find that both tax and agency issues are important determinants of security issuance decisions. In addition, we demonstrate that our specification is robust to a variety of alternative explanations which have appeared in the empirical literature.     

The Pitfalls of International Integration: A Comment on the Bush Proposal and its Aftermath

In January 2003, the Bush Administration proposed a new system for taxing corporate dividends, under which domestic shareholders in U.S. corporations would not be taxed on dividends they received, provided the corporation distributed these dividends out of after-tax earnings (the Bush Proposal). The Bush Proposal was introduced in Congress on February 27, 2003. Ultimately, however, Congress balked at enacting full-fledged dividend exemption. Instead, in the Jobs and Growth Tax Relief Reconciliation Act of 2003 (JGTRRA) as enacted on May 28, 2003, a lower rate of 15% was adopted for dividends paid by domestic and certain foreign corporations,¹ and the capital gains rate was likewise reduced to 15%. Significantly and in stark contrast to the original Bush proposal, under JGTRRA the lower rate for dividends and capital gains does not depend on any tax being paid at the corporate level.This comment will focus primarily on the international aspects of both the Bush Proposal and JGTRRA. I will not lay out the proposal or the law in any detail. Instead, I will ask whether either the Bush Proposal or JGTRRA make sense from an economic efficiency perspective when the international implications are taken into account. I will leave to others the question of whether either the Bush Proposal or JGTRRA are sensible ways to stimulate the economy (for discussion of the effect of the 2001 tax cuts see Shapiro and Slemrod, 2001, 2002). I will also omit any discussion of the distributive effects of either the Bush Proposal or JGTRRA, which have been extensively discussed elsewhere (e.g., Tax Policy Center, 2003; Burman, Gale and Orszag, 2003).     

International interest withholding taxation: Prospects for a common European policy

In 1989 the European Union member states rejected a proposal to introduce a minimum interest withholding tax of 15 percent. Some Union member states, however, remain keenly interested in bringing about some minimum level of international taxation of interest income. This suggests that member states will be asked to reconsider the issue in the near future. This paper first examines the effects of interest withholding taxes on financial markets. It then reviews some of the main aspects of potential tax reform in this area. A major challenge for any future proposal will be to satisfactorily integrate the banking system into a common interest withholding scheme.     

Exemption vs. Credit Method in International Double Taxation Treaties

This paper examines the choice of international double taxation relief methods by two small countries that mutually exchange foreign direct investment. At the first stage, each country chooses between the exemption and the credit method (as prescribed by the OECD model treaty) and at the second stage, each country sets nationally optimal non-discriminatory capital tax rates. It is shown that in the subgame perfect equilibrium both countries choose the exemption method. Mutual application of the exemption method is also shown to yield the highest welfare for each country. While the tax export effect generally induces both countries to choose inefficiently high tax rates, this effect is weakest when both countries exempt foreign earned profits from domestic taxation.     

From Destination- to Origin-Based Consumption Taxation: A Dynamic CGE Analysis

A switch from the current destination-based value-added taxation to an origin-based consumption tax will not be neutral in a world economy with international capital mobility and overlapping generations. This paper evaluates the macroeconomic and welfare effects of such a multilateral reform in a two-region, intertemporal general equilibrium model. The analysis isolates and quantifies income effects due to changes in generations' tax burdens, factor price repercussions and initial asset price adjustments, as well as efficiency effects that arise from endogenous labor supply and short run savings responses in a numerical simulation exercise.     

中国的经济增长、需求约束与税收结构

在我国目前的经济增长中,出现了投资需求过热而消费需求不足的结构性失衡状况。为此,可以把税收结构引入汉森-萨缪尔森模型,来研究税收结构对投资和消费的影响。通过实证研究发现,在税收结构中,流转税(间接税)比重的增加对投资增长有激励作用,而对边际消费倾向没有显著影响;所得税和其他税(代表了直接税)比重的增加,有利于抑制投资和过快的经济增长,相反,可以提高边际消费倾向,从而促进消费。     

Transfer pricing as a tax compliance risk

This paper studies the role of transfer pricing as a critical compliance issue. Specifically, we analyse whether and to what extent the perceived risk associated with transfer pricing responds to country-, industry- and firm-specific characteristics. Empirically, transfer pricing risk awareness is measured as a professional assessment reported by the person with ultimate responsibility for transfer pricing in their company. Based on a unique global survey conducted by a Big 4 accounting firm in 2007 and 2008, we estimate the number of firms reporting transfer pricing being the largest risk issue with regard to subsequent tax payments. We find that transfer pricing risk awareness depends on variables accounting for general tax and transfer pricing specific strategies, the types and characteristics of intercompany transactions the multinational firms are involved in, their individual transfer pricing compliance efforts and resources dedicated to transfer pricing matters.     

Is Tax Harmonization Useful?

It is a widely acknowledged result of the literature on international tax competition that an inefficient provision of public goods can only be avoided, if taxes are sufficiently coordinated. In this paper we use a model where governments use commodity and factor taxes in the tax competition game. We show that governments will always choose a second-best efficient tax structure in the Nash equilibrium if they have access to a residence-based capital tax and either a destination-based commodity tax or a labor tax. Moreover, we show that tax competition need not foreclose third-best efficiency in a world with a restricted tax policy toolkit.     

Anti-tax-avoidance provisions and the size of foreign direct investment

The paper sets up a model of a multinational firm in which the home country uses a credit with deferral or an exemption system and the host country is a low-tax jurisdiction. In this model the impact of anti-tax-avoidance provisions on the size and the growth of the foreign subsidiary is analyzed. Two main results emerge. First, anti-tax-avoidance provisions may lower the cost of capital of foreign firms quite significantly. Second, in contrast to previous models with limited financial possibilities the paper shows that a tax induced growth dynamics is absent if there are some important tax constellations.     

完善我国税法受益所有人制度的思考

受益所有人条款出现在避免双重征税协定中的股息、利息、特许权使用费的支付条款上,联合国范本及OECD范本均未对其含义进行明确规定。从联合国范本及OECD范本来看,受益所有人应该包含两个要素：一为“所有”;二为“受益”。我国在2009年以国税函[2009]601号文件的形式出台了对受益所有人的认定标准,建议从提高受益所有人条款的立法层次和对受益所有人的内涵增加直接受益的要素等方面,对我国税法的受益所有人条款进行完善。     

国际投资条约中的税收条款与发展中国家的对策

国际投资仲裁涉税案件日渐增多,国际投资领域中的税收问题凸显。美国等发达国家近年来引入各种模式的税收条款,旨在平衡东道国与外国投资者之间的税收利益。然而,不同模式的税收条款对东道国税收主权造成的影响大相径庭。发展中国家的应对之策应为:结合本国实际,相应地引入专门的税收条款,并选择宽泛的税收定义,以降低本国税收管理行为的被诉风险,保留必要的施政空间。     

我国宏观税负与经济增长的实证分析

近年来,研究有关税收和经济增长之间关系的文献较多,但从马克思的再生产理论角度来进行研究的却不多。在宋则行先生推导的国民经济增长公式的基础上,进一步引入税收和政府支出因素的同时,再做出如下假定:资本的有机构成保持不变;政府只对剩余价值征税;剩余价值率保持不变;税收不会改变产品间的比例关系。从而可以更清晰地看出我国宏观税负的总体水平。     

税收心理学的基本概念

税收遵从是近年来公共财政学研究领域的一个热点问题,其研究方法主要采用了经济分析的框架。事实上,税收遵从问题是一个复杂的行为问题,除了经济因素之外,还有一些诸如社会影响、社会规范、态度、道德伦理、价值观等因素也对税收遵从具有重要的影响。对这些因素进行研究就涉及到心理学和社会学的方法,为此甚至产生了专门的税收心理学,其主要运用社会调查、受控实验等方法研究纳税人和税收政策制定者的偏好、认知、态度等。