Why do countries combine the exemption system for the taxation of foreign profits with domestic double taxation relief?

Many European countries exempt foreign profits from domestic corporate taxation. At the shareholder level, however, all corporate profits are taxed, and double taxation relief is granted only for domestic corporate taxes. This paper attempts to rationalize this tax policy. In the presence of double taxation agreements which exempt foreign profits from domestic corporate taxation, countries may use shareholder taxes to tax these profits. The disadvantage of shareholder taxes is that they create incentives to sell domestic firms to foreigners. But double taxation relief for domestic profits may preserve domestic ownership. Our results imply that national dividend tax policies may be a factor contributing to the empirically observed home bias in investment.     

我国个人所得税改革的制度探析

我国现行个人所得税未实现其功能定位,并且还存在税制体系不调,收缴申报征管工作薄弱,重复征税等问题。因此改革应在混合型个人所得税制总体框架下,扩大征税范围,调整优化税率结构,规范费用扣除,减轻投资所得重复征税;并积极推进个人信用制度建设,加强全国税务信息网络系统建设。     

Taxation of Foreign Profits with Heterogeneous Multinational Firms

This paper analyses optimal taxation of foreign profits using a model with heterogeneous multinational firms that serve a foreign market through exports or foreign direct investment (FDI). If a firm switches from exporting to FDI, domestic activity and tax payments may decrease, stay constant or even rise because of intra‐firm trade. It turns out that, in contrast to recent claims, in all three cases, the optimal tax system implies full taxation after deduction of foreign tax payments. If the country accounts for the effects of its policy on the foreign price level, the case for taxing foreign income becomes even stronger. However, the globally optimal tax system may require exemption of foreign income from tax.     

海峡两岸对所得避免双重征税的法律构造

台湾地区"所得基本税额条例"的第12条第1项第1款自2010年1月1日起生效,确立了属地兼属人的混合税收管辖原则,使得海峡两岸税收管辖权的冲突问题凸显,也为构造对所得避免双重征税的法律制度提供了重要的实践契机。中国大陆开征的个人所得税与企业所得税和台湾地区开征的综合所得税与营利事业所得税的纳税人和征税对象绝大部分重合,这就使得海峡两岸对所得双重征税存在很大的可能及避免之必要。两岸对所得避免双重征税的法律制度,包括大陆与台湾地区的单边抵免规则和两岸短期内必须谈签的双边税收安排。     

The subsidization of small business through federal credit programs: Analytical foundations

The relationship between federal credit programs and the allocation of financial and real capital has begun to attract more attention as such programs have grown. Defenders of these programs argue that various capital market imperfections necessitate federal credit assistance. Examining the relationship between such imperfections, credit programs and the tax system should facilitate a more careful evaluation of the rationales for and the effects of various alternative policy initiatives. This paper analyzes the optimal taxation of small and large businesses when smaller businesses face higher borrowing costs, whatever the cause. The optimal tax scheme derived here implies a progressive tax applied to all businesses. In the absence of such a progressive tax scheme, federal credit programs for smaller businesses that reduce small business borrowing costs may be viewed as an imperfect substitute. Importantly, the results regarding optimal taxation (subsidization) hold even in the absence of particular capital market imperfections and without resorting to social welfare functions weighting small business output greater than large business output.     

个人所得税制调节居民收入分配问题的思考——基于美国经验的视角

个人所得税是我国调节居民收入分配的主要税种,然而目前该税种存在逆向调节趋势明显、分类征收模式导致总体累进性下降、费用扣除标准内外有别、占财政收入的比重过低、缺乏完备的信息技术支撑体系等问题,不利于实现公平分配,亟需完善。总结美国个人所得税制可资借鉴的经验,在于强调纳税人利益至上原则、满足参与约束和激励相容约束条件、加大对收入分配的调节力度,以及人性化的税收设计理念。根据＂十二五＂规划纲要所提出的改革目标,进一步改革我国个人所得税制需要从采用混合所得税制、科学设置课税单位和费用扣除标准、合理设置累进税率、将资本利得纳入征税范围、推动个人隐性收入显性化等方面入手,并做好相关配套改革。     

世贸组织框架下我国主要对外贸易税收政策研究

对外贸易税收区别于其他税收的最基本之处在于其开征课税对象仅限于参与国际贸易的商品和服务。通过深入分析关税、出口退税、反倾销税三大贸易税收政策的主要功能在内、外部因素的影响下发生的变化,针对我国三大贸易税收当前亟待解决的问题,提出了具体的策略对策。     

从财税政策角度分析中小企业融资难的问题

中小企业对国民经济和社会发展具有重要的战略意义。受金融危机影响,中小企业融资难严重制约其发展。目前,中小企业融资现状为企业税费负担加重、资金来源渠道狭窄、融资成本相对较高和信用担保体系不完善等。现行财政政策对中小企业融资主要存在财政扶持机制运作不畅、税收政策优惠力度不够、政府采购倾斜力度小及税收政策激励性不足等约束。有效解决中小企业融资难困境,政府应发挥采购的引导作用,加大财政扶持投入和结构性减税力度,完善担保机构风险补偿机制。     

Regressive Tax Rates and the Unethical Taxation of Salaried Income

In a regressive tax system, lower-income taxpayers pay larger percentages of their incomes in taxes compared to higher-income taxpayers. Although most policymakers and citizens view regressive taxation as generally unfair and unethical, the U.S. tax system taxes wage, salary, and self-employment income in a manner that deliberately subjects lower-income taxpayers to marginal tax rates that are greater than those imposed on higher-income taxpayers. As a result, some lower-income taxpayers pay a larger percentage of their income in taxes than higher-income taxpayers. In this essay, we argue that this regressiveness in the taxation of salaried income is unfair and unethical. We then evaluate President Obama’s social security plan, which would retain most of the current tax system’s regressive structure. Finally, we offer two simple alternative proposals that are non-regressive, and thus more fair and ethical approaches to the taxation of salaried income.     

Tabaksteuer in Griechenland: steuerpolitische Fehlentscheidungen

Both Germany and Greece increased tobacco taxes beginning in 2010. Tobacco taxation in both countries is primarily aimed at generating revenues and at steering the behaviour of individuals affected by the taxation. The tobacco tax structure particularly in Greece has evolved from a mainly ad valorem excise to a specific excise. The comparison of both countries shows that the German tax system is able to generate stable revenues while Greek tobacco taxation policy leads to tax evasion activities among smokers.     

Extending William Baumol’s theory on entrepreneurship and institutions: lessons from post-Second World War Greece

Abstract

This article examines William Baumol’s theory about the interaction between taxation and entrepreneurship and proposes an extension to it. The analysis shows that the traditional form of Baumol’s model, focusing mainly on the level of taxes, cannot be used in order to explain what happened in the Greek case. Utilising historical evidence from the mid 1950s to the late 1980s, this article confirms that problematic tax rules create difficulties for entrepreneurship and can lead to unproductive forms of it, as Baumol suggests. However, the focus here is on aspects of the system of taxation that Baumol’s model, examining solely tax rates and levels of taxation, neglected. It is shown that, as far as Greek entrepreneurship is concerned, the adverse effects of the system of taxation came not from the level of taxes, but mostly from a series of issues that increased its perceived unfairness and illegitimacy. Some of such issues were the complexity and frequent change of legislation, the insufficient organisation of the tax bureaus as well as the lack of adequate training and arbitrariness of the members of tax services. The evidence presented here suggests that Baumol’s model can be enriched by taking into consideration these aspects of taxation too.     

Taxation and entrepreneurship in a welfare state

Does tax policy affect the rate of self-employment in a modern welfare state? This question is analyzed empirically based on Swedish data for the entire postwar period. Available tax data indicate that payroll taxes have had a negative influence on the unincorporated rate of self-employment, though the effect is modest. No effects from regular labor income taxation or capital gains taxation are found. The paper improves upon earlier studies in that it tries to separate the effects of different taxes and uses cointegration techniques. A further extension is that it studies a Scandinavian high-tax welfare state. Earlier time-series studies analyzing self-employment and taxation have, with few exceptions, been based on data from countries with relatively low tax levels and less comprehensive welfare systems, notably the USA and the UK.     

Die falschen Angriffe auf das Ehegattensplitting

These articles debate the pros and cons of the full income-splitting tax procedure. Ernst Niemeier defends this taxation scheme, because in his opinion it is not aimed at furthering families or children but making sure that a couple does not have to pay more taxes than two singles. He argues that there are constitutional reasons to treat equal incomes equally, which he refers to as “horizontal justice”. Furthermore, he rejects evidence of a negative labour supply effect on the second earner. A team of authors at the DIW find his argumentation not at all convincing. First, they say, determining tax justice or ability to pay is ultimately a political question and cannot be determined by scientists or the courts. Thus, a constitutional determination of marriage taxation on the existing full income-splitting procedure is excessive. Second, the empirical evidence of negative labour supply effects of full income splitting for the second earner can simply not be denied. Niemeier argues why such supply effects cannot exist.     

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.     

Who Cares About Corporate Taxation? Asymmetric Tax Effects on Outbound FDI

This paper investigates whether different types of FDI are asymmetrically affected by corporate taxation. We classify investment projects according to several characteristics such as the general motivation for FDI, the type of business activity, or the degree of internationalisation of the multinational firm. Subsequently, we analyse how local taxes influence the number of German outbound investments in European countries. The analysis reveals significant asymmetries with regard to tax effects: vertically integrated investments are more sensitive to host‐country taxation than horizontal FDI; larger tax rate elasticities are estimated if business activities are considered highly mobile; and in accordance with profit‐shifting considerations, subsidiaries of more internationalised companies are less tax responsive to host‐country taxation.     

浅谈促进企业年金保险发展的税收政策

企业年金是我国多层次养老保险体系的一个重要组成部分。本文从税收制度对企业年金保险的作用出发，结合我国现阶段企业年金保险税收制度的现状及存在的问题，从完善税惠制度、明确税惠模式以及税惠资格认定等方面提出了改进建议。     

"营改增"的经济效应与增值税制度完善:一个文献综述

本文全面地阐述了"营改增"的经济效应,着重分析"营改增"对企业税负变化、 财税体制改革与收入分配的影响,及其在供给侧结构性改革背景下的作用.剖析了已有研究成果的观点、 分歧与原因.结合文献及改革趋势,认为需通过减并税率、 清理税收优惠,以进一步发挥增值税中性作用;针对部分行业对过渡性政策表现出的不适或政策缺位,未来应逐步完善立法、 慎发过渡性政策;此外,结合国内外税制变动趋势应加强征管、 增强国际竞争力.     

Optimal tax and debt policy with endogenously imperfect creditworthiness

This paper studies the patterns of optimal tax rates and borrowing in a developing country characterized by a costly tax collection. Its access to the international credit market is determined by the efficiency of the tax system, the relative bargaining power of creditors, and the outstanding debt. Country risk modifies considerably the pattern of taxes and borrowing in recessions. The tax rate exhibits strong counter-cyclical patterns in economies operating close to the credit ceiling, whereas the tax rate exhibits very few cyclical patterns in economies operating on the elastic portion of the supply of credit, where country risk factors are absent.     

Strategic Trade Policy through the Tax System

If conventional instruments of strategic trade policy are unavailable, the system of foreign profit taxation and transfer price guidelines may serve as surrogate policy instruments. In this paper, I consider a model where firms from two countries compete with each other on a market in a third country. Both firms have affiliates in the third country where (part of) the production takes place. I analyse optimal policy choices of the firms' residence countries aiming at strategically manipulating the competitiveness of their firms. I show that, first, countries prefer the tax exemption system over the tax credit system if there is no intra‐firm trade. Second, if the headquarters provide inputs for production in the affiliate, countries prefer the tax exemption system if the transfer price for these inputs is close to the headquarters' variable cost and if the residence country's tax rate is high. However, if transfer prices are high and the residence country's tax rate is low, I show that the tax credit system is an optimal tax policy choice for both countries. From a policy perspective, the view that the tax exemption system is generally the best policy response if domestic firms' competitiveness is a policy goal has to be qualified.     

WTO Rules on Direct Taxation

The widely‐followed ruling by the WTO's Dispute Settlement Body against the United States concerning the latter's FSC/ETI scheme, which led to the largest retaliation award ever authorised in a dispute at the WTO, confirmed (if there were ever any doubt) that, generally speaking, direct taxes, like indirect taxes (including tariffs), are subject to the multilateral rules of the WTO, notwithstanding efforts by tax authorities to secure specific exemptions for certain direct tax measures in these agreements. This ruling reconfirmed the traditional distinction under international trade rules between direct and indirect taxes, particularly with respect to how such taxes should be treated under the subsidy and border tax adjustment rules of the WTO. It prompted the US Congress finally to pass legislation in late 2004 to repeal the FSC/ETI scheme as part of a larger overhaul of the US corporate tax system. The most recent disputes between the United States and the European Communities over assistance to large civil aircraft (allegedly amounting in each case to even more than the FSC/ETI) also encompass direct tax measures. It would not be surprising if other WTO‐inconsistent direct tax measures were identified in the future, leading to further disputes among WTO Members. Multilateral WTO rules, which are agreed by consensus, can therefore be expected to continue to be an important factor in determining how Members shape their tax policies, as they will undoubtedly want to avoid having their tax policies successfully challenged in the WTO.