The BRICs and International Tax Governance: The Case of Automatic Exchange of Information

ABSTRACT

This article investigates the BRICs’ involvement in the adoption of Automatic Exchange of Information (AEoI) by the G20 and the Organisation for Economic Cooperation and Development (OECD) as a major breakthrough in the global fight against tax evasion. Our main questions concern the BRICs’ willingness to accept AEoI, and their agreement to the Western-dominated OECD as its institutional forum. First, we examine the domestic drivers for BRICs’ participation, as their statist model of capitalism reveals strong disincentives to join this regime and the fact that the budgetary consequences of the global financial crisis were less severe than in Western states. We argue that their agreement on AEoI results more from their persistent balance-of-payments vulnerability to illicit capital than from fiscal weakness, while also discussing the possibilities for mock compliance. Second, we review the role of the non-reciprocal US foreign account tax compliance act (FATCA) in shaping the BRICs’ preference for a multilateral AEoI-regime centred around the OECD’s Common Reporting Standard (CRS). Last, we show that the BRICs’ acceptance of the OECD resulted from pragmatic interests and receiving ownership over the process, together with the absence of coercive mechanisms within the CRS-regime that could fundamentally undermine their sovereignty in this domain.     

On Teaching a Fractured Macroeconomics

One of the most interesting results in the tax evasion literature is that an increase in the income tax rate would increase tax compliance. Despite its peculiarity, this result has gained acceptance as a cornerstone for further developments of the rational tax evasion model. However, because of the mathematical format by which it is conveyed, this counterintuitive result has remained inaccessible to undergraduate students as well as to noneconomists. The author first introduces the rational tax evasion model in a nonmathematical style that is accessible to any reader. Second, he shows that the behavioral predictions of the rational tax evasion model can easily be obtained using a simple graphical representation of the optimum condition that involves the derivation of a demand curve for tax compliance.     

Are international deposits tax-driven

This paper investigates the impact of tax policy on international depositing. Non-bank international deposits are shown to be positively related to interest income taxes and to the presence of domestic bank interest reporting. This suggests that international deposits are in part intended to facilitate tax evasion. At present, only part of international interest flow are covered by either non-resident interest withholding taxes or international exchange of information. This incomplete coverage may be a reason that these policies currently appear to have little impact on international depositing.     

Revenue Sharing and Information Exchange under Non‐discriminatory Taxation*

The international exchange of tax information, and its merits compared to withholding taxation, has emerged as a central topic in international tax policy. We characterize and compare the outcomes that emerge, in a two‐country world, with and without information exchange, under the assumption that countries are unable to tax residents and non‐residents differentially. The analysis focuses on the role of asymmetries in country size (capturing a key feature of tax havens) and on the impact and potential desirability of schemes to share the revenue raised by withholding (as under the new EU savings tax arrangements) or (more innovatively) as a consequence of information exchange. We show that, irrespective of any difference in country size, it is in the interests of both countries, in terms of tax revenue, that all revenue collected from non‐residents be transferred to the residence country—which would entail taking the EU practice even further from the norm, but is currently the standard in relation to information exchange. A withholding scheme with revenue fully reallocated in this way gives both countries more revenue than does information sharing, whatever the allocation under the latter.     

Dynamic Tax Evasion with Habit Formation in Consumption*

We model the optimal intertemporal decision of an agent who chooses tax evasion and consumption, over an infinite lifetime horizon, where consumption is driven by habits. We find the following: (i) tax evaders reduce consumption in the early stages of habit accumulation and increase it over time; (ii) habit formation has a dampening effect on tax evasion; (iii) neglecting tax evasion can lead to habit overestimation; (iv) the effect of the tax rate on tax evasion is ambiguous; (v) heavy fines are more efficient than frequent controls in reducing tax evasion.     

Do your tax problems make tax evasion seem more justifiable? Evidence from a survey experiment

Taxpayers often view tax rules and filing processes as complicated. I study whether the perceived tax uncertainty among peers makes tax evasion more acceptable among the general public. I find strong supportive evidence for this hypothesis using a survey experiment and a large representative sample of the German population. Providing randomized information that others are uncertain about how to file their taxable income decreases individual support for tax compliance. This suggests that subjects judge tax evasion less harshly in response to this peer information. Studying related heterogeneous treatment effects, I find that both older and left-wing subjects are more responsive to tax uncertainty of others. Less harsh views on evasion are persistent for very high compliance levels in a follow-up survey.     

Rethinking strategy and geopolitics: Critical responses to globalisation

Rethinking geopolitics is a key feature of those disciplines concerned with rearticulating the site and nature of political space and political community in an age of globalisation causing much social protest and concern. The article focuses upon how social movements challenging globalisation are rearticulating and rethinking, through their objectives and strategies, the practices, meaning and site of state sovereignty and ‘the (geo)political’. The article focuses upon the way critical movements such as the Emiliano Zapata (Zapatista) Army of National Liberation (EZLN) are engaging with new ways of thinking about, representing and constructing political space and the relationship between the local and the global whilst cultivating an inclusionary national community project(s). The article argues that the EZLN engages in a struggle which may provide an insight into the possibility of cultivating alternative and genuinely democratic civil societies and inclusive political communities that transcend the exclusionary cartography and institutions of the neoliberal state.     

论偷逃税违法以主观故意为要件

偷逃税违法以主观故意为要件,主要理由是：偷税一词是建国后的新造词,专门用来指称故意弄虚作假的现象。现行《税收征收管理法》有关偷税的法条表述,应当解释为包含了主观故意的内容。从刑法角度看,主观故意是偷逃税犯罪的要件,而刑法上对故意的考虑,反过来制约着税收执法,要求税务机关在对偷逃税违法行为定性处罚时考虑主观故意因素。此外,从《税收征收管理法》相关条款和国家税务总局的文件上分析,主观故意也是偷逃税定性处罚必须考虑的因素。     

构建我国纳税人诉讼制度的理论基础

纳税人诉讼制度是公民财政监督权的具体体现,是实现财政民主与财政法治的重要途径。文章逐次分析了纳税人诉讼制度的政治学、经济学以及法学基础,指出“税收契约”、“税收价格”和“．税收债权债务理论’’都是纳税人诉讼赖以建立的理论基础,而宪法中关于人民主权、财产权、监督权的规定是纳税人诉讼得以建立的直接依据。     

关于税收筹划的若干思考

在我国，税收筹划逐步被有关人员所重视。纳税人要把握好税收筹划与偷税、避税的界限；纳税人可以从投资决策、融资决策和应纳的主要税种等方面进行税收筹划。     

Estimating the revenue losses of international corporate tax avoidance: the case of the Czech Republic

International corporate tax avoidance by multinational enterprises likely lowers the Czech Republic’s corporate income tax revenue, but it is not clear by how much. To clarify this I first review existing estimates of the revenue losses of international corporate tax avoidance to government revenue worldwide. I then discuss revenue estimates relevant for the Czech Republic and develop a few new, albeit only illustrative, ones. None of the existing research focused on the Czech Republic nor did the six recent international studies I examine provide reliable estimates for the Czech Republic. The extrapolations from these studies result in a revenue loss of a quite wide range with a median of 10% of current corporate income tax revenues. The other newly prepared estimates, based on firm-level and aggregate data, are of similar magnitude. I conclude with a discussion of these rough estimates as well as questions for further research and policy recommendations.     

The Determinants of Location Choices of China's ODI: Institutions,Taxation and Resources

China has become the third largest source of outward direct investment (ODI). This paper studies how institutions in the host countries affect the location choices of China’s ODI. Based on a deal-level sample from 2002–2011, this paper empirically tests how political institutions, political stability, government effectiveness, regulatory quality, rule of law and contrd of corruption in the host countries affect the location choices of China’s ODI. On top of these institutional factors, we study the effects of tax evasion and natural resources in host countries, and their interactions with institutional factors. We find that political institutions in the host countries are not major concerns of the ODI, while government effectiveness, regulatory quality, and control of corruption have significant effects on the locations of ODI. In addition, China’s ODI tends to avoid countries with strict legal systems. Tax evasion and resources are also major motives of China’s ODI. General institutional quality and tax evasion are substitutes in China’s ODI location decisions.     

Global capital markets,direct taxation and the redistribution of income

Standard fiscal theory suggests that taxation should be heaviest on the least mobile factors of production – for both efficiency and revenue reasons. A shift in tax burdens from capital to labour as economies become globally integrated is thus justified. This theoretical tradition (founded by Ramsay and continued by Mirrlees and Lucas) assumes by construction that profit taxes reduce investment and growth; and while sensitive to inter-generational equity, sidesteps the issue of income distribution within generations. In contrast, starting from Keynes’ critique of these assumptions and building on modern endogenous growth models, it can be shown that profit taxation is not necessarily injurious to productive investment. In practice, moreover, the effect of globalisation has not been to reduce tax rates on capital, but rather to erode the tax base itself (i.e. ‘tax evasion’). Improved information exchange between tax authorities, which is now being driven by fiscal insolvency in developed countries, would allow tax incidence to be shifted so as to improve income distribution within OECD countries. Such cooperation could also permit the replacement of the current discretionary system of fiscal transfers from rich to poor countries (‘development aid’) by equitable sharing of global capital tax revenue.     

Does a lower (higher) labour force participation rate imply greater (lower) income tax evasion? An exploratory empirical inquiry for the U.S.

This exploratory study seeks to add to the income tax evasion literature by investigating a heretofore ignored potential determinant of aggregate federal personal income tax evasion in the U.S., namely, the labour force participation rate. It is hypothesized that the higher (lower) the labour force participation rate, the lower (greater) the degree of tax evasion. The empirical estimation supports this hypothesis, finding that a one unit (one percentage point) increase (decrease) in the labour force participation rate leads to a 9.1% decrease (increase) in income tax evasion. Thus, the declining labour force participation in recent years implies increased tax evasion problems for the U.S.     

Income Underreporting and Tax Evasion in Italy: Estimates and Distributional Effects

The paper estimates the extent of evasion of personal income tax (PIT) in Italy by integrating two methods that the literature has previously applied separately. The consumption-based method introduced by Pissarides and Weber (1989) is used to estimate misreporting of income in micro data collected in the household IT-SILC survey. We adopt an econometric specification close in spirit to that of Feldman and Slemrod (2007), which allows us to estimate income misreporting at different rates for different income sources. The misreporting estimates are then used in the discrepancy method to correct the incomes compared with administrative registered data. The comparison provides new estimates of evasion of personal income tax by type of income, region and income class. The estimates are used to improve microsimulation analyses of the distributional impact of tax evasion.     

Markovian Social Security in Unequal Societies

In this paper, we develop a dynamic political‐economic theory of social security. We analytically characterize a Markov perfect equilibrium and find that the interaction between Markovian tax policy and tax distortion on private investment in human capital shapes an intertemporal policy rule, linking taxes positively over time. By allowing current taxpayers to influence their own future social security benefits, the positive intertemporal tax linkage provides political support for social security. Moreover, this positive tax linkage leads to a negative correlation between wage inequality and the size of a nation's social security system, consistent with the empirical pattern observed across OECD countries.     

国际洗税行为分析

近年来 ,在中国境内 ,跨国纳税人从事国际逃税、国际避税活动屡见不鲜 ,出口骗税十分猖獗。阿林汉姆 -桑德姆预期效用最大模型、本杰米尼 -梅塔尔逃税决策相互依赖模型等理论对此不能作出恰当的解释。本文首次揭示了国际洗税行为 ,并发现上述跨国纳税人纳税不服从行为与国际洗税密切相关。本文还通过建立一个博弈模型对国际洗税内在动机进行了剖析 ,并在此基础上提出了政策建议。     

The Dutch experience: Assessing the welfare impacts of two consolidation strategies using a heterogeneous-agent framework

Between 1990 and 2010, the Dutch government pursued two successful fiscal adjustments: first, in 1995–2002, through a pure expenditure-based strategy and second, in 2004–2007, through a mixed strategy based on social transfer cuts and tax increases. In order to assess welfare and, in particular, inequality effects involved in each episode, we built a general equilibrium model with heterogeneous-agent capable of exploring the relationship between fiscal policy variables and the endogenous cross-section distribution of income, wealth and welfare.The results confirm that, for the Netherlands, a pure expenditure-based strategy is slightly superior relative a (partial) revenue-based one. In spite of positive welfare gains, the model predicts significant transition costs in both episodes due to depletion of insurance capacity, higher inequality and output losses. Moreover, as supported by the data, the model simulations show an improvement of the net foreign asset position in the sequence of the debt-consolidation processes. Finally, the two consolidation episodes, described throughout the paper strengthen the relevance of political institutions as important successful factors.     

Tax evasion,social norms,and economic growth

We propose a theoretical model to account for the negative relationship between tax evasion and economic development. More precisely, we integrate tax morale into a dynamic OLG model of tax evasion. Tax morale is modeled as a social norm for tax compliance. We show that accounting for such nonpecuniary costs of evasion may explain (a) why the share of evaded taxes over GDP decreases when countries grow and (b) that tax morale is positively correlated with the level of GDP per capita. Finally, a higher tax rate increases aggregate evasion and the number of evaders when taxpayers decisions are interdependent.     

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.