The impact of bilateral tax treaties: A multi-country analysis of FDI inflows into India

This paper models the role of tax treaties in promoting foreign direct investment (FDI) with the help of panel data for 14 countries for the period 1993–2011. A fixed effects (least squares dummy variable) model is developed that captures macroeconomic factors such as gross domestic product (GDP) and per capita income (PCI) in ratio form of home to host country. It also includes bilateral tax treaties as a determinant of FDI inflow. The results show that GDP is a major determinant that is demand driven and per capita income is a major determinant that is supply driven. FDI openness of the home countries and population are also significant determinants. The introduction of the treaty had a positive impact on FDI inflows into India. We get largely significant and positive results for the ‘age of the treaty effect’, especially, in the case of Germany, Switzerland and Japan. The main contribution of the paper is to show that both presence and ‘age of treaty’ are important determinants of FDI flows to India. Further, fundamentals like GDP and PCI are major variables that influence FDI inflows.     

Trade openness,tax reform and tax revenue in developing countries

This article investigates empirically whether the effect of tax reform (involving the progressive replacement of trade tax revenue with domestic tax revenue) in developing countries' tax revenue performance (measured by tax revenue‐to‐GDP ratio) depends on the degree of trade openness of these countries. The analysis has used an unbalanced panel data set of 95 developing countries over the period 1981–2015 and the two‐system GMM approach. Results suggest that tax reform is positively and significantly associated with tax revenue performance in developing countries, with the magnitude of this positive effect increasing as countries experience a higher development level. Additionally, and more importantly, countries that further open up their economies to international trade enjoy a higher positive effect of tax reform on tax revenue than countries that experience a lower degree of trade openness. Therefore, these findings should help dissipate the concerns of policymakers in developing countries that greater openness to international trade would further erode their tax revenue, including by lowering their international trade tax revenue. In fact, the implementation of an appropriate tax reform in the context of greater trade openness would generate higher tax revenue, while concurrently allowing countries to reap the well‐known benefits of international trade.     

Tax Impact on Corporate Income Remittances to and from Japan and the United States

This study examines the combined impact of bilateral tax treaties and domestic tax policies on corporate income remit- tances to and from Japan and thc United States. Thc study calculates the two-way flows of corporate reminanccs between these two coun- tries and 100 other countries. We find very significant differences in the tax treatment by these two countries across bolh remittance methods and countries. The study recommends that both govern- ments seek ways to promote greatcr worldwide uniformity in tax treatment of corporate income remittanccs.     

A macroeconomics perspective on international coordination in sales taxes

This article investigates how international coordination vis-à-vis sales tax policies affects the welfare of participating countries. A country's tax policies have asymmetric effects on the pricing behaviors of domestic and overseas producers. International cooperation endogenizes the externality that improves the purchasing power of foreign residents, but at the cost of its own residents’ work efforts. The first-best taxes are lower than in the noncooperative case. When world welfare is utilitarian, smaller economies may experience welfare losses from cooperation under the weak income effect of sales tax. We propose a coordinated tax rule that all countries agree to employ.     

刍议国际投资协定中的税收仲裁机制——以中国的缔约实践为例

为减少与包括WTO协定和避免双重征税协定在内的其他涉税条约争端解决机制之间的冲突,特别是,避免原有的投资者与国家间投资仲裁机制对本国税收主权的过度限制,中国晚近缔结的国际投资协定引入了专门的税收仲裁机制。这一尝试值得期许。然而,该税收仲裁机制仍存在诸多的不足,这可能会削弱其应有的作用。对此,中国应参考有关国家的实践,作出相应的调整。     

The optimal tax on antebellum US cotton exports

The US produced about 80% of the world’s cotton in the decades prior to the Civil War. How much monopoly power did the US possess in the world cotton market and what would have been the effect of an optimal export tax? This paper estimates the elasticity of foreign demand for US cotton exports and uses the elasticity in a simple partial equilibrium model to calculate the optimal export tax and its effect on prices, trade, and welfare. The results indicate that the export demand elasticity for US cotton was about −1.7 and that the optimal export tax of about 50% would have raised US welfare by about $10 million, about 0.3% of US GDP or about 1% of the South’s GDP.     

Who benefits from partial tax coordination?

In this paper, we investigate whether partial tax coordination is beneficial to countries within and outside a tax union, in which countries are supposed to compete in taxes and infrastructure. Our results demonstrate that a subgroup of countries agreeing on a common tax rate can harm both member and nonmember states. This is in contrast to the classical findings that partial tax harmonisation is Pareto improving. When a minimum tax rate is imposed within a tax union, we demonstrate that it does not necessarily improve the welfare of the member countries. Moreover, both the high‐tax and low‐tax countries can be worse off. This conclusion is at odds with the classical result that a high‐tax country benefits from the imposition of a lower tax bound.     

The true art of the tax deal: Evidence on aid flows and bilateral double tax agreements

Of a total of 2,976 double tax agreements (DTA s), some 60% are signed between a developing and a developed economy. As DTA s shift taxing rights from capital‐importing to capital‐exporting countries, the latter inherently benefit more from the agreements. In this paper, we argue that capital exporters use foreign aid to incite capital importers into signing DTA s. We demonstrate in a theoretical model that in a deal, one country does not trump the other, but that the deal must be mutually beneficial. In the case of an asymmetric DTA , this requires compensation from the capital‐exporting country to the capital‐importing country. Examining DTA s that are signed between donor and recipient countries between 1991 and 2012, and using a fixed effects Poisson model, we find that bilateral foreign aid commitments increase by 22% in the year of the signature of a DTA . Evaluated at the sample mean, this translates into around US$ six million additional aid commitments in a DTA signatory year.     

我国流转税与所得税最优比例关系的实证分析

在中国 ,流转税和所得税都与经济增长呈现统计上显著的负相关 ,而与人均GDP以及城乡居民储蓄表现为较好的正相关 ;流转税和所得税分别和国内生产总值建立的三次多项式的回归模型很好地拟合了流转税和所得税的变化轨迹。本文通过 1 992～ 2 0 0 2年税收数据拟合模型 ,分别得到我国经济增长最大化时 ,最优的流转税、所得税占GDP的比率 ,并得出目前的税改重点应为增大所得税的比率的结论。     

OECD国家的经济增长与税收结构变化

本文分析了1995~2009年OECD国家的税收结构随经济发展而发生的变化。研究发现,用人均GDP衡量的经济增长对OECD国家的税收结构没有显著影响,而旅游收支、失业率和资本形成等代表经济结构的变量以及代表政府政策取向的政策变量对税收结构的影响显著。从总体来看,OECD国家的税收结构目前处于稳定状态,开始于20世纪70年代的发达国家税制结构改革已基本完成,＂双主体＂的税制结构已基本形成。     

欧盟各国税收制度竞争与协调现状分析

伴随着欧洲经济一体化的不断扩大,欧盟各国普遍采用税收竞争的手段来吸引外来投资,改善本国企业竞争力,对于这种税收竞争所带来的后果,各国评价不一.文章试图通过对欧盟各国税收既有竞争又希望协调的现状进行分析,来探讨如何在欧盟内部消除有害税收竞争,实现税收协调的目标.     

The Effect of Tax Treaties on Multinational Firms: New Evidence from Microdata

This paper uses affiliate‐level data from Swedish multinationals to examine the impact of tax treaties on both overall affiliate sales and the composition of those sales. In line with previous results, we find little evidence for an effect of treaties on the level of total sales. We do, however, find that a tax treaty increases the probability of investment by a firm in a given country. In addition, we find that a treaty reduces exports to the parent but increases imports of intermediate inputs from the parent. This is consistent with treaties increasing the effective host tax. This suggests that tax treaties impact the behaviour of multinationals along some dimensions but not along others.     

我国省际劳动、资本、消费有效税率的估算与比较

国际上衡量实际税收负担的一般方法为平均有效税率,采用这一国际通行方法,核算了1998－2012年我国各省级劳动、资本收入以及消费支出的平均有效税率,以反映这三种要素的真实负担情况,并将它与世界其它国家进行了比较研究。结果表明：各省劳动收入有效税率则呈上升态势,资本有效税率呈先下降再上升趋势,消费有效税率呈现不规则上升趋势;资本收入有效税率大大高于劳动收入和消费支出的有效税率;各省劳动和消费的有效税率还处于世界平均偏下水平,而资本有效税率处于世界平均偏上水平;地区比较来看,东部地区的劳动、资本、消费有效税率最大,西部次之,中部最低。表明西部地区的税负水平偏高,应该探索能够降低西部地区税负的有效途径,均衡地区之间的税收负担。     

An Analysis of Double Taxation Treaties and their Effect on Foreign Direct Investment

Double taxation treaties (DTTs) are intended to eliminate double taxation and thereby increase foreign direct investment (FDI). DTTs are also meant to prevent tax evasion which previous literature argues has a negative effect on FDI. Using matching econometrics and a large data set of developed to less developed country-pairs, I show that despite their intentions and the significant costs of entering into DTTs, the treaties have no effect on the flows of FDI. An analysis of the treaties in conjunction with the related domestic tax legislation shows why this is the case. Developed countries unilaterally provide for the relief of double taxation and the prevention of fiscal evasion regardless of the treaty status of a host country. This eliminates the key economic benefit and the risk that these treaties would otherwise create for the FDI location decisions of multinational enterprises.     

社会保障税的税源与税率研究——基于2010—2050年人口预测数据

社会保障税费改革争论已久,实质问题不在于谁负责征税,而在于区分税费性质,理顺社会保障体系的结构。基于社会保障税的税源与税率的确定,以《国家人口发展战略研究报告》发布的人口数据为基础,以国民基础养老金为例,测算2010—2050年中国社会保障税的税率、财政支出占比与GDP占比,结果表明:国民基础养老金作为纯公共品,应由政府通过税收的方式为其筹集资金,资金来源的可行方式是征收社会保障税。     

Quantifying the evolution of world trade, 1870–1949

The typical narrative regarding the evolution of world trade prior to World War II refers to a secular rise starting around 1870 and a subsequent collapse beginning in 1914. This narrative, however, is based on measures of trade openness that do not fully take into account purchasing power differences across countries. Due to lack of alternative data, the measures employed in the existing literature are typically based on non-PPP-adjusted trade data denominated by PPP-adjusted GDP data. The present paper seeks to resolve this inconsistency by constructing new trade share estimates for 62 countries, representing 90% of world GDP, for the period from 1870 to 1949. Our estimates combine historical import and export figures with non-PPP-adjusted GDP values that we estimate via the short-cut method. Our estimates confirm qualitatively the narrative of a dramatic rise and fall of world trade over this period. Yet, they indicate that this rise and fall was quantitatively much more pronounced. We find that trade shares were on average 38% higher than previously documented and the world's level of trade openness in 1913 was comparable to that in 1974.     

How to Balance the Outcomes of the Economic Partnership Agreements for Sub‐Saharan African Economies?

Since 2002, the Sub‐Saharan African countries ( except South Africa which already has a free‐trade agreement with the EU ) have embarked on free‐trade agreement negotiations with the European Union. These arrangements will replace the Cotonou scheme, which requires these countries to eliminate their tariffs on ‘substantially’ all their European imports. Based on a general equilibrium analysis, this study estimates the potential effects of these agreements by considering different levels of reciprocity in the commitments of the Sub‐Saharan African countries. It shows that the ‘standard’ EU proposal, whereby Sub‐Saharan African countries would cut tariffs on 80 per cent of their European imports, would not be enough to balance the outcome of the Economic Partnership Agreements. As a result of the asymmetries between European and African protections and supply‐side capacities, African countries could experience a balance of trade deficit of USD 1.8 billion associated with a 0.1 per cent decrease in GDP. This proposal, which also induces an industrial restructuring to the benefit of the agro‐processing industries, will create a significant fiscal burden. A lesser level of commitment could largely mitigate these unfavourable results; by reciprocating tariff eliminations on only 60 per cent of their European imports, African countries would reduce the trade imbalance and fiscal losses induced by these agreements by 21 and 51 per cent respectively.     

Fighting Software Piracy: Some Global Conditional Policy Instruments

This study examines the efficiency of tools for fighting software piracy in the conditional distributions of software piracy. Our paper examines software piracy in 99 countries over the period 1994–2010, using contemporary and non-contemporary quantile regressions. The intuition for modelling distributions contingent on existing levels of software piracy is that the effectiveness of tools against piracy may consistently decrease or increase simultaneously with the increasing levels of software piracy. Hence, blanket policies against software piracy are unlikely to succeed unless they are contingent on initial levels of software piracy and tailored differently across countries with low, medium and high levels of software piracy. Our findings indicate that GDP per capita, research and development expenditure, main intellectual property laws, multilateral treaties, bilateral treaties, World Intellectual Property Organisation treaties, money supply and respect for the rule of law have negative effects on software piracy. Equitably distributed wealth reduces software piracy, and the tendency not to indulge in software piracy because of equitably distributed wealth increases with the increasing software piracy levels. Hence, the negative degree of responsiveness of software piracy to changes in income levels is an increasing function of software piracy. Moreover, the relationships between policy instruments and software piracy display various patterns: U-shape, Kuznets-shape, S-shape and negative thresholds. A negative threshold represents negative estimates with the increasing negative magnitude throughout the conditional distributions of software piracy. We also discuss the policy implications of our study.     

Do Swedish multinationals pay less in taxes than domestic firms?

In recent years, there has been growing concern that multinational enterprises (MNE s) engage in strategic tax planning in order to shift profits to low‐tax jurisdictions. This common perception is generally confirmed by empirical evidence, which is foremost provided for countries with high corporate taxes and relatively complex tax systems. We investigate whether multinational firms in a country with a comparatively more competitive tax system undertake profit shifting. We do this using detailed census data from corporate income statements and balance sheets filed by Swedish manufacturing firms between 1997 and 2007. We detect profit shifting by comparing MNE s with (purely) domestic firms. In particular, we identify systematic differences in tax payments, earnings (before interest and taxes) and equity ratios between multinational and comparable domestic firms based on propensity score matching. In addition, we examine the tax behavioural impact of acquiring multinational status using difference‐in‐differences estimations and/or propensity score matching. Our results reveal that the extent to which multinational firms have lower tax payments than their domestic counterparts depends on their production characteristics and foreign market outreach. In particular, we find evidence indicating that firms operating in few foreign markets and firms that become multinational engage in profit shifting from Sweden.     

从环境税制国际实践看我国污染税制度建设

税收作为政府使用的一种重要经济手段,具有资源配置、调控经济等职能,美国、欧盟等已经将征税列入环境保护的有效措施。我国目前虽然也设有与环境保护相关的税种,但缺乏环境保护专门的税种,有关规定也不健全,对环境保护的税收优惠单一,缺乏针对性和灵活性。我国应将部分排污费改为环境污染税,使其成为环境税制的主体税种,调整现行的资源税,扩大征收范围,提高征收标准,完善计税依据,并对相关的消费税进行一定的调整。