Neutral Taxation of Shareholder Income

A Norwegian tax reform committee recently proposed a personal tax on the realized income from shares after deduction for an imputed risk-free rate of return. This paper describes the design of the proposed shareholder income tax and shows that it will be neutral with respect to investment and financing decisions and decisions to realize capital gains, provided that full loss offsets are granted. Thus the tax allows some non-distortionary double taxation of corporate equity income. With an appropriate choice of tax rates, it also solves the problem of income shifting under a dual income tax. JEL Code: H24, H25     

Deferred Shareholder Taxation – Implementing a Neutral Business Tax in the European Union

This paper proposes the replacement of the corporate income tax by shareholder-based capital income taxation. Our proposal would guarantee investment neutrality of taxation and reduced tax compliance costs. The proposal is based on the S-base cash flow tax. Under the S-base tax, transactions within the corporate sector are not taxable and only transactions between shareholders and corporations are subject to tax. In contrast to existing S-base cash flow tax systems, tax deductibility of investments is deferred. Rather, the acquisition costs and capital endowments are compounded at the capital market rate and are set off against future capital gains. Dividends and withdrawals are fully taxable at the shareholder level. Because of the deferral of the tax payments our proposal is called ‘Deferred Shareholder Tax’ (DST). The DST exhibits the same neutrality properties as the traditional cash flow tax. Moreover, the compounded inter-temporal credit method ensures that it is neutral with respect to the decision between domestic and foreign investment. To increase acceptance of the DST, current taxpayers’ documentation requirements will be reduced rather than extended. Our proposal could be realised in a single EU country or in all member states of the EU.     

Removing Homeownership Bias in Taxation: The Distributional Effects of Including Net Imputed Rent in Taxable Income

The income tax systems of most countries entail a favourable treatment of homeownership, compared to rental‐occupied housing. Such ‘homeownership bias’ and its consequences for a wide range of economic outcomes have long been recognised in the economic literature. Although a removal of the homeownership bias is generally advocated on efficiency grounds, its distributional implications are often neglected, especially in a cross‐country perspective. In this paper, we aim to fill this gap by investigating the first‐order effects, in terms of distribution of income and work incentives, of removing the income tax provisions favouring homeownership. We consider six European countries – Belgium, Germany, Greece, Italy, the Netherlands and the UK – that exhibit important variation in terms of income tax treatment of homeowners. Using the multi‐country tax benefit model EUROMOD, we analyse the distributional consequences of including net imputed rent in the taxable income definition that applies in each country, together with the removal of existing special tax treatments of incomes or expenses related to the main residence; thus, we provide a measure of the homeownership bias. We implement three tax policy scenarios. In the first, imputed rent is included in the taxable income of homeowners, while at the same time existing mortgage interest tax relief schemes and taxation of cadastral incomes are abolished. In the two further revenue‐neutral scenarios, the additional tax revenue raised through the taxation of imputed rent is redistributed to taxpayers, through either a tax rate reduction or a tax exemption increase. The results show how including net imputed rent in the tax base might affect inequality in each of the countries considered. Housing taxation appears to be a promising avenue for raising additional revenues, or lightening taxation of labour, with no inequality‐increasing side effects.     

Taxable income,future profitability,and stock returns

Prior research suggests that investors behave ‘as if’ taxable income contains information about future performance by providing evidence of a positive association between taxable income and stock returns. We draw on the fundamental analysis literature and provide direct evidence on this assertion by examining whether taxable income predicts future pretax performance. We find that taxable income positively predicts future pretax cash flows, pretax book income, and ‘Street’ pretax earnings, suggesting that taxable income provides incremental information to book income regarding performance. Moreover, we find a positive association between taxable income and analysts’ pretax forecasts, consistent with analysts utilizing the information in taxable income when forming earnings expectations. We do not find an association between taxable income and future analyst forecast errors, implying analysts do not overreact or underreact to taxable income's performance signal. Overall, we find that taxable income provides a signal of fundamental value and corroborate the implications of prior research.     

Taxpayers' responsiveness to tax rate changes and implications for the cost of taxation in Sweden

Historically, labor supply elasticities have been used to evaluate tax policy and predict tax revenue effects. They are likely to underestimate taxpayers' response to tax rate changes, and hence to underestimate changes in potential tax revenues, however, because they measure only how taxpayers alter hours worked. Taxpayers can also respond to tax rate changes by altering, for instance, their work effort and form of compensation. An alternative measure that accounts for these responses as well as hours worked is the elasticity of taxable income. This paper estimates the elasticity of earned taxable income for Swedish taxpayers using two different approaches and a number of control variables and the 1990/1991 tax reform as a “natural experiment”. The preferred elasticity estimates fall in the range of 0.4–0.5, comparable with recent estimates for the U.S. and larger than most of the labor supply elasticity estimates used to evaluate tax policy in Scandinavia previously, which suggests that deadweight losses are two to three times higher than previously thought. JEL Classification H21 · H24 · H31 · J22     

Corporate and personal income tax declarations

Decisions by firms and individuals on the extent of their tax payments have generally been treated as separate choices. Empirically, a positive relationship between corporate and personal income tax evasion can be observed. The theoretical analysis in this paper shows that a manager's decision on the firm's behaviour will be independent of his personal preferences if the gain from reducing corporate tax payments is certain, as in the case of tax avoidance. If, however, the firm evades taxes so that the manager's income depends on whether the firm's activities are detected or not, corporate and personal income tax evasion choices cannot be separated. Jel Code H 24 · H 25 · H 26     

Tax Responses at Low Taxable Incomes: Evidence from Germany*

The desirability of a particular tax system depends on how different taxpayers react to it. Exploiting the personal allowance threshold and detailed German tax administration data, this paper examines responses at low taxable incomes to extend previous findings. Taxpayers bunch at the allowance threshold, and more so with non-wage income. Unlike in other studies, wage earners also bunch, at least if they file a tax return, while incomes gross of deductions do not. Deductions account for a sizeable share of the sharp bunching mass of taxpayers with non-wage income. A machine learning analysis identifies which deduction items predict such sharp bunching. The pattern of results suggests that local intensive-margin real responses induce moderate deadweight loss.     

欧共体法院判例对成员国个人所得税扣除制度的推进

《欧共体条约》中没有对直接税的具体规定,欧共体①立法机关也没有对直接税进行立法。但是,欧共体法院②通过案例判决,间接地发展了个人所得税的扣除制度,明确了相关的税收处理办法:应退还临时居民纳税人超额缴纳的工薪所得税;对非居民应按扣除商业费用后的净所得征税;"狭隘"归集抵免制因阻碍成员国间的资本自由流动而被废止。     

The Elasticity of Taxable Income in New Zealand*

This paper reports estimates of the elasticity of taxable income with respect to the net‐of‐tax rate for New Zealand taxpayers. The relative stability of the New Zealand personal income tax system, in terms of marginal rates, thresholds and the tax base, provides helpful conditions for deriving these estimates. The elasticity of taxable income was estimated to be substantially higher for the highest income groups. Changes in the timing of income flows for the higher income recipients were found to be an important response to the announcement of a new higher rate bracket. The marginal welfare costs of personal income taxation were consistent across years, being relatively small for all but the higher tax brackets. For the top marginal rate bracket of 39 per cent, the welfare cost of raising an extra dollar of tax revenue was estimated to be well in excess of a dollar. Implications of the findings are that: disincentive effects of high top marginal rates can be substantial even when labour supply responses are small; the welfare costs of increases in top marginal tax rates can be high; and announcement effects of tax policy changes can lead to considerable income shifting between time periods.     

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.     

合并纳税制度的国际比较及对中国的启示

发达国家为了提高本国企业的国际竞争力、吸引投资,普遍实施企业集团合并纳税制度。我国现行的合并纳税制度在保持税收公平和税收中性、控制国内税收流失和国有资产流失、国际税收协调等方面存在诸多不完善之处,不仅使中国企业集团在国际市场上处于不利位置,也制约了企业的稳定发展。因此,应通过比较和分析中国与其他国家的企业集团合并纳税制度,找出中国合并纳税制度的不足之处,并加以完善。     

新旧企业所得税制度的差异比较

从2008年1月1日起,我国的企业所得税制度合二为一。新的企业所得税制度与原制度相比,在纳税人、纳税义务、税率、收入、扣除、资产的税务处理、应纳税所得额的计算、境外所得税收抵免、税收优惠和反避税管理等方面均有突出的变化,标志着新制度更具有科学性、规范性和国际性,对推进我国社会主义市场经济建设,促进改革开放和社会主义和谐社会的建立都具有深远的意义。     

Barriers to Entry in the Unlisted Securities Market: the Significance of Administrative Expenses

This paper analyses the significance of administrative expenses incurred by a comprehensive sample of firms obtaining quotation on the Unlisted Securities Market and Official List in the 1980s. It is concerned with the extent to which barriers to entry in the new issue market arising from the existence of high fixed costs of obtaining a quotation established in previous research have been reduced as a result of the introduction of the USM. A comparative analysis is undertaken, examining the relative costs of new issues in the USM and the Official List, together with a study of whether total expenses are affected by the route chosen for ultimate progression to the Official List. The research examines the extent to which cost variation can be attributed to differences in characteristics of the issue and of the firms themselves so as to generate continuing and significant economies of scale. Finally, the paper considers briefly whether competition in the new issue market has been associated with a reduction over time in the real cost of expenses, or whether, as has been alleged, USM costs are again increasing at a faster rate than inflation.     

中国亏损上市公司盈余管理手段有效性研究

本文选取我国沪深A股亏损上市公司为研究样本,对2010年首次亏损而在2011年扭亏的上市公司是否会在扭亏年度内进行盈余管理,以及运用何种手段进行盈余管理及并对其有效性进行分析.运用模型以及多元线性回归方法进行实证研究发现：首次亏损上市公司财务报表中的营业外收支、资产减值准备、营业成本、投资收益及管理费用等更容易受到企业的操控.因此建议,为提高各方对会计信息的识别能力,企业的股东、债权人和监管机构等利益相关者要警惕此类指标的异常变动.     

ESTIMATING THE TAX BENEFITS OF DEBT

The standard approach to valuing interest tax shields assumes that full tax benefits are realized on every dollar of interest deduction in every scenario. The approach presented in this paper takes account of the possibility that interest tax shields cannot be used in some scenarios, in part because of variations in the firm's profitability. Because of the dynamic nature of the tax code (e.g., tax-loss carrybacks and carryforwards), it is necessary to consider past and future taxable income when estimating today's effective marginal tax rate. The paper uses a series of numerical examples to show that (1) the incremental value of an extra dollar of interest deduction is equal to the marginal tax rate appropriate for that dollar ; and (2) a firm's effective marginal tax rate (and therefore the marginal benefit of incremental interest deductions) can actually decline as the firm takes on additional debt.
Based on marginal benefit functions for thousands of firms from 1980–1999, the author concludes that the tax benefits of debt averaged approximately 10% of firm value during the 1980s, while declining to around 8% in the 1990s. By taking maximum advantage of the interest tax shield, the average firm could have increased its value by approximately 15% over the 1980s and 1990s, suggesting that the consequences of being underlevered are significant. Surprisingly, many of the companies that appear best able to service debt (i.e., those with the lowest apparent costs of debt) use the least amount of debt, on average. Treasurers and CFOs should critically reevaluate their companies' debt policies and consider the benefits of additional leverage, even if taking on more debt causes their credit ratings to slip a notch.     

VAT and agriculture: lessons from Europe

Little has been written about the treatment of agriculture under the value added tax (VAT). This article attempts to fill the void by surveying and evaluating the situation in the Member States of the European Union (EU) and some other countries. Farmers are often exempted from VAT for administrative and political reasons. But this means that the VAT on their inputs cannot be ‘washed out’ through the tax deduction/credit mechanism. It then has to be borne by the farmers themselves or becomes an indeterminate and capricious element in consumer prices. To compensate farmers for the uncompensated VAT on inputs, the EU has devised a flat-rate scheme that permits them to charge a presumptive rate (approximately equal to the effective VAT rate on sector-wide inputs) on their sales to taxable agro-processing firms which, in turn, are permitted to take a deduction for this flat-rate addition from the VAT on their sales. Obviously, the flat-rate scheme is an arbitrary way of trying to achieve equal treatment between exempt and taxable farmers and between exempt farm products and other taxable goods and services. Full taxation, subject to the general threshold, appears to be the preferred choice.     

社会保障税税基的确定

社会保障税税基的确定是开征社会保障税需要解决的一个关键问题。为了体现社会保障税效率和公平兼顾的原则，个人纳税部分应设起征点和最高限征额，而企事业单位纳税部分不设。各地应将个人月平均工资低于当地月平均工资的一定比例（如50％）作为个人缴纳社会保障税的起征点；同时，要规定被保险人的最高纳税收入基数。起征点和最高限征额均应根据经济发展水平和物价指数的变化进行调整。企事业单位应以全部职工的工资总额作为税基。     

Why Do Countries Mandate Accrual Accounting for Tax Purposes?

This study investigates why countries mandate accruals in the definition of corporate taxable income. Accruals alleviate timing and matching problems in cash flows, which smoothes taxable income and thus better aligns it with underlying economic performance. These accrual properties can be desirable in the tax setting as tax authorities seek more predictable corporate tax revenues. However, they can also make tax revenues procyclical by increasing the correlation between aggregate corporate tax revenues and aggregate economic activity. We argue that accruals shape the distribution of corporate tax revenues, which leads regulators to incorporate accruals into the definition of taxable income to balance the portfolio of government revenues and expenditures. Using a sample of 26 OECD countries, we find support for several theoretically motivated factors explaining the use of accruals in tax codes. We first provide evidence that corporate tax revenues are less volatile in high accrual countries, but high accrual countries collect relatively higher (lower) tax revenues when the corporate sector grows (contracts). Critically, we then show that accruals and smoother tax revenues are favored by countries with higher levels of government spending on public services and uncertain future expenditures, while countries with procyclical other tax collections favor cash rules and lower procyclicality of corporate tax revenues.     

TAX PROGRESSIVITY AND CORPORATE INCENTIVES TO HEDGE

If a company faces some form of tax progressivity—that is, its marginal tax rate increases over the firm's expected range of reported taxable income—corporate hedging can reduce the firm's expected tax liability by reducing the volatility of pre-tax income. In a study described in this article, the authors used simulation methods to investigate the extent to which tax progressivity arises from various provisions of the tax code, such as the AMT and tax carryforwards and carrybacks. Based on their analysis of over 80,000 COMPUSTAT firm-year observations, the authors find that, in about 50% of the cases, corporations face effective tax functions that exhibit progressivity. The other 50% of cases are about evenly divided between firms that are tax neutral and those facing tax schedules that are "regressive" (again, over the relevant range of expected reported income).
For those companies facing progressive tax functions, the authors estimate that the projected average tax savings from a 5% reduction in the volatility of taxable income is about 5.4% of the expected tax liabilities. However, the distribution of expected reductions is highly skewed, in extreme cases exceeding 40% of the total tax liability. Most of these extreme cases are small to medium-sized companies, since such firms are much more likely to meet the two conditions for achieving large tax benefits: (1) expected pretax income that is close to zero; and (2) sufficiently volatile income that the firm (in the absence of hedging) expects to report losses in some years. In sum, small to medium-sized companies experience the greatest tax benefits from hedging.     

优化营商环境视域下网络虚构交易的税法因应

我国正积极优化营商环境以推动公平竞争.网络虚构交易作为新兴商业策略,目前正被网络经营者滥用.已有研究多侧重关注如何维护竞争秩序,而较少关注税制因素对竞争秩序的影响.理论上,网络虚构交易所涉增值税、企业所得税等税款均可申请退税.这在一定程度上间接鼓励网络虚构交易的发生,事实上构成了对守法经营者的税制歧视,最终会扭曲电子商...