The Resource International tax coordination for a second-best world (part II)
International tax coordination for a second-best world (part II)
Resource Information
The item International tax coordination for a second-best world (part II) represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item International tax coordination for a second-best world (part II) represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- In the first part of this article the basic framework for international tax coordination has been laid out. It has been established that neither the ability-to-pay principle nor the benefit principle provides a guiding light when the allocation of taxing rights between countries is concerned. Likewise, the standard requirements of CEN, CIN and CON do not give a full and systematic picture either. In recent years, the dynamics of tax competition have ensured that market power of governments and the attractiveness of countries for investors play a major role when it comes to the shaping of unilateral and bilateral tax provisions on international taxation of business. Against this background, it has been proposed in the first part of this article to rely on a "continuity approach", which tries to avoid abrupt and discontinuous changes in the tax treatment of different sources of income without taking one-dimensional solutions for granted. This has been exemplified for the choice between permanent establishments and subsidiaries. In the second part of this article, this analysis is extended to the choice between portfolio and direct investment (portfolio shares v. controlling shareholdings), the choice between debt and equity and the exploitation of intellectual property. While there are good reasons to align treatment for small and large shareholdings, the specific treatment of interest versus dividends or of royalties versus other forms of business income may be justified depending on the mechanics of tax competition in a given situation
- Language
-
- eng
- eng
- Label
- International tax coordination for a second-best world (part II)
- Title
- International tax coordination for a second-best world (part II)
- Language
-
- eng
- eng
- Summary
- In the first part of this article the basic framework for international tax coordination has been laid out. It has been established that neither the ability-to-pay principle nor the benefit principle provides a guiding light when the allocation of taxing rights between countries is concerned. Likewise, the standard requirements of CEN, CIN and CON do not give a full and systematic picture either. In recent years, the dynamics of tax competition have ensured that market power of governments and the attractiveness of countries for investors play a major role when it comes to the shaping of unilateral and bilateral tax provisions on international taxation of business. Against this background, it has been proposed in the first part of this article to rely on a "continuity approach", which tries to avoid abrupt and discontinuous changes in the tax treatment of different sources of income without taking one-dimensional solutions for granted. This has been exemplified for the choice between permanent establishments and subsidiaries. In the second part of this article, this analysis is extended to the choice between portfolio and direct investment (portfolio shares v. controlling shareholdings), the choice between debt and equity and the exploitation of intellectual property. While there are good reasons to align treatment for small and large shareholdings, the specific treatment of interest versus dividends or of royalties versus other forms of business income may be justified depending on the mechanics of tax competition in a given situation
- Citation source
- In: World tax journal. - Amsterdam. - Vol. 2 (2010),
- http://library.link/vocab/creatorName
- Schön, W
- Geographic coverage
- International
- Language note
- English
- http://library.link/vocab/subjectName
-
- harmonization of tax
- source principle of taxation
- residence principle of taxation
- tax competition
- ability to pay
- benefit principle
- capital export neutrality
- capital import neutrality
- subsidiary company
- PE
- Label
- International tax coordination for a second-best world (part II)
- Note
- 20100423
- Other control number
- wtj021004.pdf
- Label
- International tax coordination for a second-best world (part II)
- Note
- 20100423
- Other control number
- wtj021004.pdf
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/International-tax-coordination-for-a-second-best/FilxEv1-HjE/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/International-tax-coordination-for-a-second-best/FilxEv1-HjE/">International tax coordination for a second-best world (part II)</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/International-tax-coordination-for-a-second-best/FilxEv1-HjE/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/International-tax-coordination-for-a-second-best/FilxEv1-HjE/">International tax coordination for a second-best world (part II)</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="http://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
