Journal articles on the topic 'Corporations Taxation Accounting'
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1
Govind, Har. "India: Taxation of multinational corporations." Intertax 14, Issue 6/7 (June 1, 1986): 148–56. http://dx.doi.org/10.54648/taxi1986048.
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Schultz, Thomas D., and Kyle Scott. "Puerto Rico: The Evolution of America's Corporate Tax Haven." ATA Journal of Legal Tax Research 12, no. 1 (March 1, 2014): 17–40. http://dx.doi.org/10.2308/jltr-50746.
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ABSTRACT We examine the taxation of corporate income earned in the Commonwealth of Puerto Rico and how the repeal of the possession tax credit available under Internal Revenue Code (IRC) §936 resulted in many U.S. companies converting former possessions corporations into controlled foreign corporations. Although Puerto Rico is a U.S. territory, the conversions highlight that corporations organized under the laws of the Commonwealth generally are foreign corporations for U.S. tax purposes. A U.S. Senate Subcommittee reports Microsoft Corporation shifted offshore the recognition of nearly one-half of its U.S. net retail sales revenue for the period 2009–2011 by transferring intellectual property rights to a controlled subsidiary in Puerto Rico. We find that the corresponding U.S. tax benefits are significant compared to the credits once claimed under IRC §936, and over 20 percent of Standard & Poor's (S&P) 500 firms were in a similar position to avoid federal taxation by shifting income between political subdivisions of the United States.
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Rosembuj, Tulio. "Hybrid Entities Why Not Tax Pass-throughs as Corporations?" Intertax 40, Issue 5 (May 1, 2012): 298–318. http://dx.doi.org/10.54648/taxi2012035.
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It doesn't make sense to allow certain taxpayers to choose whether they are a corporation or not. The US check-the-box rules, since 1997, have produced a boost to international tax arbitrage. The hybrid entities are the result of the discordances between different jurisdictions, qualifying them at the same time as corporation or pass-through. The misuse of hybrid entities offered a powerful tool for tax minimization on local and foreign earnings. It is not by chance that the financial sector took clear advantages through the special purpose vehicles, structured arrangements, loan and credit transactions and parking of assets for tax purposes. The hybrid entities or reversal hybrid entities meant an incentive for aggressive tax planning. The right solution should be the taxation of pass-through entities as corporations: the partnership income and the attribution income to the partners.
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Blétière, Emmanuel Raingeard de la, and Daniel Gutmann. "CC(C)TB and International Taxation." EC Tax Review 26, Issue 5 (September 1, 2017): 233–45. http://dx.doi.org/10.54648/ecta2017026.
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On 25 October 2016, the European Commission released two proposals: one on a Common Corporate Tax Base (COM (2016) 685 Final.) (‘the CCTB Draft’) and one on a Common Consolidated Corporate Tax Base (COM (2016) 683 Final.) (‘the CCCTB Draft’). If these draft directives (‘the CC(C)TB Drafts’) were to be adopted, they would significantly change the tax landscape for companies operating throughout the European Union as well as for companies which are established in a third country but perform activities within the EU. The goal of this article is not to provide for an overall description of the features of the CCTB and the CCCTB Drafts. It is rather to give an overview of the main provisions containing a cross-border element and to assess to what extent these new instruments may possibly collide, not only with EU primary law, but also with bilateral (or even multilateral) conventions on double taxation. As a matter of fact, the CC(C)TB drafts do not only cope with the definition of new base rules for taxation of corporations acting within the European Union. Many corporations established in the European Union have branches and subsidiaries in other EU Member States as well as in third countries. Conversely, many corporations established outside the European Union perform their activities on the European market through branches and subsidiaries. It is therefore clear that by changing the rules applying to the definition of corporate income and to cross-border activities, the CC(C)TB Directives would indirectly impact the tax burden of multinational enterprises. Besides, important provisions contained in the CC(C)TB drafts apply explicitly to income which have their source outside the European Union. The question how these new European territoriality rules will coexist with international tax treaties is therefore crucial to assess the impact of the harmonization process within the European Union. The relationship between CC(C)TB and international taxation is however a very complex matter to study, as it raises both general questions regarding the interaction between different sources of normativity (treaties vs directives; treaties vs fundamental freedoms; directives vs fundamental freedoms) and very technical questions linked to the way the proposed provisions are worded. Potential problems of incompatibility are all the more numerous as one of the major feature of CCTB and CCCTB consists in the enactment of new rules regarding territoriality and tax avoidance, which may worsen the taxpayer’s situation compared to existing rules (even compared with the anti-tax avoidance directive). Provisions affecting international taxation are spread in different sections of the CCTB and CCCTB drafts, with the effect that a coherent vision of the global impact of these drafts on international taxation is not easy to unveil. This complexity of the topic explains why the authors of this article consider that a necessary preliminary step in the study consists in displaying, in a first section, a broad overview of the relationships between the CC(C)TB Drafts and the EU and international legal orders. This will provide an opportunity to assess how these draft directives interact, not only with fundamental freedoms, but also with double taxation treaties. The authors will refer to those principles throughout the article, when potential conflicts are identified. A second section will be devoted to the scope of the CC(C)TB Drafts and to the analysis of their impact on situations involving a third country. The goal of this section will be to determine to what extent corporations which are either established in a third country or perform their activities in such a country are actually covered by the provisions of the draft directives. The third section will provide more details on the territoriality rules which are laid down by
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Zielke, Rainer. "Taxation of Capital Gains in the European Union, Norway, and Switzerland: An Empirical Survey with Recommendations for EU Harmonization and International Tax Planning." Intertax 37, Issue 6/7 (June 1, 2009): 382–405. http://dx.doi.org/10.54648/taxi2009040.
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The present survey analyzes for the first time the taxation of capital gains in the European Union, Norway, and Switzerland and makes recommendations for European Union (EU) harmonization and international tax planning. The main issue is the question whether the national and international rules on the taxation of capital gains from cross-border sales of shares are an appropriate basis for taxation of multinational groups of affiliated corporations or whether these rules should better be harmonized. In a first step, the nature of capital gains taxation is discussed and the principles of capital gains taxation of cross-border sales of shares are examined both according to Community Law and to the Organization for Economic Co-operation and Development (OECD) Model Convention (OECD MC). Thereupon and in a second step, these rules are examined and measured by these criteria in domestic, outbound, and inbound cases in terms of Article 13 (5) OECD MC. Finally, recommendations for harmonization for capital gains taxation in the EU and for international tax planning are made on the basis of the analysis of the empirical survey.
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Gujarathi, Mahendra R. "GlaxoSmithKline Plc.: International Transfer Pricing and Taxation." Issues in Accounting Education 22, no. 4 (November 1, 2007): 749–59. http://dx.doi.org/10.2308/iace.2007.22.4.749.
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This comprehensive case intends to develop your understanding of the complexities involved in the international transfer pricing and taxation of intangible assets. The backdrop for the case is GlaxoSmithKline's $5.2 billion settlement in 2006 with the U.S. Internal Revenue Service. You are required to provide possible rationales for the positions advocated by the Company as well as the IRS. You are also required to present calculations under different transfer pricing methods, identify the most appropriate method, compute Foreign Tax Credits for different scenarios, and suggest possible strategies for multinational corporations to reduce the odds of negative settlements with tax authorities.
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Forrester, Emily. "Is the State Aid Regime a Suitable Instrument to Be Used in the Fight Against Harmful Tax Competition?" EC Tax Review 27, Issue 1 (January 1, 2018): 19–35. http://dx.doi.org/10.54648/ecta2018003.
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The aim of this article is to analyse the suitability of the State aid regime as an instrument to fight harmful tax competition. There are several negative effects of such ‘race to the bottom’ competition, which act as significant barriers to the functioning of the internal market. Application of the State aid rules has been troubled and heavily influenced by the fluctuating policy objectives of the Commission. There has been a long established intersect between State aid and taxation, although, such overlap has been expanding and ever encroaching within the taxation policies of Member States, which is presently considered sovereign territory. The current investigations into numerous multinational enterprises, for instance Apple, signify a radical new approach adopted by the Commission, one which could not have been predicted by neither the Member States nor corporations. It is evident that the Commission have adopted the State aid rules as a tool to attack harmful tax competition, and to ensure that selective corporations are not receiving unbridled benefits through favourable tax rulings. However, the State aid regime is not and should not be used as an anti-competition instrument which allows the Commission to scrutinize every new tax measure adopted by Member States. Such developments are inappropriate and represents a radical shift away from precedent, creating uncertainty in the area of international taxation. Harmonization or regulatory competition seems a more suitable fit for the issue of harmful tax competition, plaguing the internal market.
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Miller, Karen C., J. Riley Shaw, and Tonya K. Flesher. "Taxation of Personal Use of Corporate Aircraft: Should Income Equal the Deduction?" ATA Journal of Legal Tax Research 5, no. 1 (January 1, 2007): 99–115. http://dx.doi.org/10.2308/jltr.2007.5.1.99.
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Business growth and ease of mobility have played a significant role in the increasing use of corporate aircraft through the 21st century. Along with the increased use of corporate aircraft, personal use of corporate aircraft has also been on the rise. With this increased use, the tax treatment of the personal use of corporate aircraft has become much more visible and controversial. This paper tracks the changes in the law and focuses on the tax policy issues related to the equity in the reporting of income by the employee and the deduction claimed by the corporation. Specifically, this paper addresses the three-fold problem related to the current inequities of the current and proposed laws: What amount should be included as compensation by the employee as a fringe benefit for the personal use of company-owned aircraft? How much should the employer deduct for the operating cost of the aircraft for personal use? Should these amounts, compensation and deduction, be equal? The paper also addresses the horizontal inequities imposed by the current laws upon shareholders, different types of employees, corporations, and private citizens.
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Dowd, Tim, Christopher Giosa, and Thomas Willingham. "Corporate Behavioral Responses to the TCJA for Tax Years 2017-2018." National Tax Journal 73, no. 4 (December 1, 2020): 1109–34. http://dx.doi.org/10.17310/ntj.2020.4.09.
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We analyze the initial corporate response to the 2017 enactment of the “Tax Cuts and Jobs Act” (TCJA). The TCJA changed many corporate tax provisions, including a reduction of the corporate statutory tax rate from 35 percent to 21 percent effective in 2018 and sweeping changes to the taxation of income earned abroad by U.S. corporations. Based on a sample of U.S. corporate tax returns, we find that corporations accelerated deductions into 2017 and delayed income into 2018, thereby minimizing their taxes. We estimate an income and deduction shifting tax elasticity of -0.11 and 0.08, respectively. Additionally, we study detailed tax returns of 81 large corporations to understand how those changes impacted them.
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McDonald, John F. "International Real Estate Review." International Real Estate Review 14, no. 2 (August 31, 2011): 240–57. http://dx.doi.org/10.53383/100141.
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This paper is a theoretical examination of untaxed and taxed entities that invest in real estate. The standard advice to real estate investors is to avoid using entities that are subject to taxation (such as C corporations in the U.S.) and employ entities that are not subject to taxation (such as limited liability companies, S corporations, and real estate investment trusts in the U.S.) in order to avoid double taxation of income. This paper shows that, in most situations, untaxed entities place a greater value of a given real estate property than does a taxed entity, which implies that taxed entities are at a distinct disadvantage at competing in the market for property. However, this conclusion is reversed if untaxed entities use a large amount of financial leverage compared to taxed entities and the borrowing rate for both is greater than the risk-free rate.
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Nilsson, Therese, and Petra Inwinkl. "The Swedish Taxation on Loans from Foreign Companies." EC Tax Review 20, Issue 2 (April 1, 2011): 84–93. http://dx.doi.org/10.54648/ecta2011009.
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On 1 January 2010, the Swedish government changed the rule on taxation of prohibited loans between Swedish companies and their shareholders and extended the regulation to loans granted by foreign companies. By changing the rule to also comprise foreign companies, the government aims to eliminate tax avoidance. The inclusion of foreign corporations in national legislation has been subject to criticism by the consultative bodies in the government bill and in the legal debate. The expression of discontent is due to the fact that the extension of the statutory rules to foreign companies does not comply with the freedom of establishment. This article aims to provide a response as to whether the changes of the rule on taxation of prohibited loans are compatible with the freedom of establishment and, consequently, whether the Swedish government commits, by the extension of the statutory rules to foreign companies, a breach of the right of the freedom of establishment.
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Van Brederode, Robert F. "The Impact of Science and Technology on Taxation." Intertax 41, Issue 12 (December 1, 2013): 628–37. http://dx.doi.org/10.54648/taxi2013061.
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It is impossible to provide a complete overview of all occurrences where taxation exercises influence on or is influenced by technology and science. However, it is feasible to demonstrate the interaction of technology, science and taxation in a number of selected areas. This article describes this dynamic as it relates to empirical legal research, which has the purpose of determining whether a particular law or process is actually achieving its stated objectives; the use of statistical science in tax auditing to determine the level of compliance through the analysis a relatively small part of the available date (sample); the introduction of technology in tax administration to streamline and enhance the efficiency of processing vast amounts of data, and the different complexities encountered by developed versus developing countries; and finally, the use of software technology, i.e., ERP systems and tax engines, by global corporations to improve their tax compliance and tax planning, especially in the area of sales and consumption taxes and customs duties.
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Evers, Lisa. "The Cross-border Taxation of Dividends in the Case of Individual Portfolio Investors: Issues and Possible Solutions." EC Tax Review 21, Issue 1 (February 1, 2012): 17–32. http://dx.doi.org/10.54648/ecta2012003.
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So far, the field of cross-border taxation of dividends paid to individual investors in the European Union (EU) Member States has not been subject to harmonization. The differences in the Member States' tax systems give rise to obstacles to the internal market. As a consequence, individual investors may be discouraged from investing in shares of foreign corporations. Hence, the benefits of international risk diversification are not fully exploited. The discussion of possible solutions to these issues has recently received a new impetus as the European Commission held a consultation on the issues of cross-border dividend taxation in Spring 2011. In this article, we discuss the alternative solutions pointed out by the European Commission and present our genuine proposal. We show that dividends paid to individual investors should not be taxed at source by drawing on a set of normative criteria comprising conformity with European Law, efficiency, simplicity, and equity considerations. We furthermore argue that the abolition of withholding taxes should be accompanied by introducing automatic exchange of information. The analysis of alternative reform options is preceded by a brief, yet comprehensive summary of the taxation of dividends in the EU Member States highlighting the shortcomings of the current dividend taxation.
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Kraft, Gerhard, and Sigrid Zielinski. "Like-kind Exchanges Pursuant to Section 1031 Internal Revenue Code and their Consequences under German CFC-rules." Intertax 41, Issue 3 (March 1, 2013): 153–58. http://dx.doi.org/10.54648/taxi2013013.
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On the basis of sound economic reasoning, numerous tax systems have provisions that allow for tax-free exchanges of like-kind property. When the property is sold after the exchange the gain will usually be taxed so that it is in fact not a tax-free exchange but rather a deferral of taxation until the sale of the property. After a brief overview of the basic like-kind exchange rules under the US Internal Revenue Code (IRC) and the basic concepts of the German Controlled Foreign Corporations (CFC-) rules, this article discusses the possible consequences of a like-kind exchange of US property by a US corporation, owned and controlled by shareholders resident in Germany under German CFC-rules. As a few examples will demonstrate, a like-kind exchange under US law could - if certain conditions are met - lead to the application of German CFC-rules thereby reversing the non-recognition event. In these instances, German CFC legislation overreaches the basic purpose of CFC-rules - to prevent or reduce abuse and designs for tax evasions.
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Jacobs, Otto H. "The effects of business taxation on shareholders financing of corporations - An analysis of taxation concepts in France. Germany and the United States." Intertax 17, Issue 11 (November 1, 1989): 464–76. http://dx.doi.org/10.54648/taxi1989090.
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Zielke, Rainer. "2014 Income Tax Reform in Norway." Intertax 42, Issue 6/7 (June 1, 2014): 481–93. http://dx.doi.org/10.54648/taxi2014045.
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On 30 April 2015, the individual income tax declaration for 2014 is due in Norway. The present article is the only English language publication worldwide that enables the reader to calculate the income tax and tax on net worth of individuals for 2014 on the basis of the individual income tax reform 2014 in Norway, including rules impinging on cross-border relations. This is of particular importance today, as Norway - due to its rich natural resources - has become an important country both economically and in terms of immigration. Today the country has international connections based on economic relations and immigration. The present article provides a praxis oriented overview on the 2014 tax changes in Norway with special respect to the taxation of individuals, the taxation of corporations, the real estate tax and other. After that the resulting effects of the tax changes on the tax burden of individuals in 2014 are outlined and calculated.
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Zielke, Rainer. "2013 Income Tax Reform in Norway." Intertax 42, Issue 1 (January 1, 2014): 51–61. http://dx.doi.org/10.54648/taxi2014006.
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On 30 April 2014, the individual income tax declaration for 2013 is due in Norway. The present article is the only English language publication worldwide that enables the reader to calculate the income tax and tax on net worth of individuals for 2013 on the basis of the individual income tax reform 2013 in Norway, including rules impinging on cross-border relations. This is of particular importance today, as Norway - due to its rich natural resources - has become an important country both economically and in terms of immigration. Today the country has international connections based on economic relations and immigration. The present article provides a praxis-oriented overview on the 2013 tax changes in Norway with special respect to the taxation of individuals, the taxation of corporations, the real estate tax and other. After that the resulting effects of the tax changes on the tax burden of individuals in 2013 are outlined and calculated.
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Raghuwanshi, Himanshu. "Country Note: Abolition Of Ddt In India: A Treat For Foreign Investors?" Intertax 49, Issue 12 (December 1, 2021): 1025–35. http://dx.doi.org/10.54648/taxi2021103.
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The Indian government eliminated the much maligned dividend distribution tax (DDT) through Finance Act 2020. The abolishing of the DDT marks a return to the shareholder regime of dividend taxation (hereinafter ‘shareholder regime’). Foreign enterprises (generally multinational corporations) aiming to do business in India through subsidiaries or enterprises that already have subsidiaries in India can benefit from this change. This article analyses the tax impact of this change when an Indian subsidiary distributes its profits to its parent or holding company. Thus, the paper presents a tabular representation of taxation in the DDT regime and the shareholder regime and compares them. To present the complete scenario, the paper also analyses different profit distributing mechanisms other than dividends that are used by companies – specifically, the buyback of shares and share capital reduction. Finally, limited liability partnership (LLP) firms offer another vehicle for companies to conduct business in India. Thus, the paper also analyses the taxation aspects of an LLP distributing profits to its partner company. The return to the shareholder regime will allow non-residents to avail beneficial tax rates provided for dividend taxation in double taxation avoidance agreements (DTAAs) signed by India with other countries. Thus, the final section of this article discusses the mechanisms that are in force to prevent treaty shopping. The principal purpose test (PPT) brought in by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS) (Multilateral Instrument or MLI), the threshold of beneficial owners found in most DTAAs, and India’s domestic general anti-avoidance rule (GAAR) are analysed to determine the essential requirements of these mechanisms. CFC, Individuals, BEPS, Action 3, Brazil.
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Malyshev, M. K. "Assessing Finance Interaction of Chemical Industry Corporations with State." Vestnik of the Plekhanov Russian University of Economics, no. 6 (December 22, 2021): 112–25. http://dx.doi.org/10.21686/2413-2829-2021-6-112-125.
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The article assessed interaction of state and chemical industry corporations by criteria of budget making, tax burden and managerial impact. The appraisal was made on the basis of methodological tools worked out by the author. Within the period from 2012 to 2020 earnings of corporations of chemical industry producing mineral fertilizers grew and exceeded tax revenues of regions of their location, which caused an increase in companies’ taxation potential. However, analysis of tax payments to the budget system by profit tax, property tax, income tax and VAT did not confirm the growth in this potential. A rise in dividends, payments for losses were typical for enterprises, as well as increasing amount of dividends surpassing net profit. The goal of the article is to identify the level of finance interaction efficiency between state and enterprises of chemical industry. The following enterprises of chemical industry producing mineral fertilizers acted as the object of the research: the public company ‘Apatit’ (Vologda region), the public company ‘Akron’ (Novgorod region) and the public company ‘Dorogobuzh’ (Smolensk region). This choice was stipulated by location of these enterprises in regions with weakly-diversified economic structure and serious dependence on the budget-forming enterprise. The information base of the research was formed by works by Russian and overseas authors dealing with chemical industry development, finance accounting of the companies, data of the Federal Taxation Service and the Treasury of Russia.
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Krishnamurti, Chandrasekhar, and M. S. Narasimhan. "Dividend taxation, ownership structure and payout policy: Evidence from India." Corporate Ownership and Control 4, no. 3 (2007): 287–302. http://dx.doi.org/10.22495/cocv4i3c2p6.
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Despite the widespread criticism against double taxation of dividends, most countries follow the policy of taxing the same income twice – once when the corporations earn it and a second time when shareholders receive it. Critics of the double taxation policy clamor for its abolition citing the economic inefficiencies it engenders. In 1997, the Indian government eliminated double taxation of dividends by exempting dividend income from personal taxes but requiring the firms to pay a 10% tax on the amount of dividend distributed. Using this rule change as a natural experiment, we examine the impact of this rule change on firm valuation. We show that elimination of double taxation on dividends is not unambiguously beneficial to the stockholders of the firm. We find that tax status and ownership structure play a significant role in explaining the direction of observed changes in valuation. An interesting finding of this paper is that shareholders seem to value visibility. Visible firms are subject to the disciplining effect of more stringent disclosures in the financial press. We do find pervasive evidence that firms increased their dividends subsequent to rule change. We however, do not find any association between the change in dividends and ownership structure
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Moser, Till. "The German Exit Taxation According to Section 6 Foreign Transaction Tax Law and Section 50i Income Tax Law: Current Developments and Areas of Concern." Intertax 43, Issue 10 (October 1, 2015): 610–14. http://dx.doi.org/10.54648/taxi2015059.
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German residents moving abroad face an exit taxation regime under section 6 Foreign Transactions Tax Law if they hold shares in domestic or foreign corporations. In 2013, the respective provision was amended by section 50i Income Tax Law, which was again fundamentally reformed in July 2014. This provision has been accused to be vague and ambiguous and, as a consequence, implies serious application problems in practical terms both for the fiscal authorities and the tax payer, with tremendous consequences for foreign investment in Germany. Given this background, the following article revisits the most challenging problem areas and offers possible solution approaches.
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Letizia, Giulia. "The Recent Restrictive ECJ Approach to Exit Tax and the ATAD Implementation." EC Tax Review 29, Issue 1 (March 1, 2020): 33–37. http://dx.doi.org/10.54648/ecta2020004.
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The article discusses the development of the European Court of Justice approach to exit tax and the perspective adopted by ATAD (Anti-Tax Avoidance Directive) exit tax provisions. Following a first European Court of Justice (ECJ) orientation according to which Member States were allowed to tax corporations on latent capital gains at the time of the transfer of the place of effective management to another Member State, but deferring the collection until the actual realization of the assets to five yearly instalments, the more recent ECJ approach allows an exit tax imposed upon the transfer regardless of the actual realization, payable over a five-year period. On the lines of the second ECJ approach, ATAD provides a mandatory harmonized exit tax imposed at the moment of the exit, allowing a deferral over five yearly instalments. It represents the first form of income taxation provided by a EU Directive, which does not take into account if some EU Member State did not have any exit tax. The ECJ shifting and the restrictive ATAD approach on exit tax may determine a wider rethinking of the movement of companies within the EU having the ATAD exit tax provision partially emptied the content of the freedom of establishment principle. Mandatory harmonized exit tax, ATAD, Corporate taxpayers, Latent capital gains, Freedom of establishment principle, ECJ shifting, Income taxation, Deferral of taxation, Discrimination, Income inclusion approach
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Letizia, Giulia, and Francesco Capitta. "National Grid Indus Case: Consequences under an Italian Perspective." EC Tax Review 21, Issue 5 (October 1, 2012): 277–82. http://dx.doi.org/10.54648/ecta2012027.
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The article describes the impact of the decision of the European Court of Justice 'National Grid Indus' on Italian rules regarding exit taxation. The former Italian legislation prescribed the immediate taxation of unrealized capital gains, except if a Permanent Establishment (PE) is maintained in Italy, without distinguishing between the establishing of the amount of taxes and their recovery. In the meantime, the European Commission opened an infringement procedure against Italy with regard to the rules on exit tax. In January 2012, such rules have been modified in compliance with the principles established in National Grid Indus, allowing Member States to tax corporations on latent capital gains at the time of the transfer of the place of effective management to another Member State, but deferring the collection until the actual realization of the assets. This change carries out a series of problematic aspects concerning the scope of application of the new provision with regard to the transfer of permanent establishments of foreign enterprises in Italy, the tax basis of the assets transferred and, in particular, the interaction with the Merger Directive.
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Purwantini, Heni. "Minimizing Tax Avoidance by Using Conservatism Accounting Through Book Tax Differences." International Journal of Research in Business and Social Science (2147-4478) 6, no. 5 (September 19, 2017): 55–67. http://dx.doi.org/10.20525/ijrbs.v6i5.765.
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The research’s first purpose is to analyze directly conservatism accounting influence towards book tax differences and tax avoidance. The second purpose is to analyse indirect influence towards tax avoidance through book tax differences. The research is conducted to companies enlisted in Indonesian Stock Exchange and belongs to LQ45 during 2013 to 2015. The number of companies sample taken by purposive sampling is 23 corporations, therefore total observation is 69 observations. The acquired data analysed by path analysis. This research conclude that conservatism accounting practice significantly influence book tax difference practice but did not influence tax avoidance. Conservatism accounting practice is also having no influence towards tax avoidance committed by book tax differences. This book tax difference is only significantly influential to commit tax avoidance. This research can contribute in taxation field as input in tax planning formulation.
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Walsh, Robert J. "An historical framework for the Federal taxation of dividend and interest payments in the US." Accounting History 6, no. 1 (May 2001): 61–74. http://dx.doi.org/10.1177/103237320100600105.
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This paper presents an historical analysis of the deductibility of interest expense and the nondeductibility of dividend payments by corporations in the US over three distinct periods of tax policy. Many in government, industry and academia have debated the disparate tax treatment between interest and dividends. Given the nature of this debate, this paper seeks to identify the origins of the difference in tax treatment of corporate interest and dividend payments. This study aims to inform policy deliberations by examining events during three periods, namely the Civil War era, the implementation of the Revenue Act 1909 through to 1939, a “watershed year” in US taxation, and the period from 1939 to the present day.
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Moser, Till. "The Provisions of the EU Anti-Tax Avoidance Directive Regarding Controlled Foreign Company Rules: A Critical Review Based on the Experience with the German CFC Legislation." Intertax 45, Issue 10 (October 1, 2017): 606–23. http://dx.doi.org/10.54648/taxi2017052.
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The EU Anti-Tax Avoidance (ATA) Directive of 12 July 2016 introduced common minimum standards for fighting tax avoidance practices by the Member States of the EU. Besides interest limitation rules, rules on exit taxation, general anti-abuse rules as well as measures against hybrid mismatches, the ATA Directive provides minimum standards for the treatment of Controlled foreign corporations (CFCs). It is evident that the respective provisions follow, at least partly, the handwriting of the German CFC Rules, which are the oldest within the European Union (EU) and rank among the oldest in the world. In this context, the following article critically reviews the provisions of the ATA Directive regarding CFC Rules, taking into account the experience with the German CFC legislation.
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Kluzek, Marta, and Katarzyna Schmidt-Jessa. "CAPITAL STRUCTURE AND TAXATION OF COMPANIES OPERATING WITHIN NATIONAL AND MULTINATIONAL CORPORATE GROUPS: EVIDENCE FROM THE VISEGRAD GROUP OF COUNTRIES." Journal of Business Economics and Management 23, no. 2 (February 25, 2022): 451–81. http://dx.doi.org/10.3846/jbem.2022.15634.
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The aim of this study is to review the level of debt and the impact of taxation on the capital structure of companies operating within national and multinational corporate groups in the countries of the Visegrad Group. In the research, financial data was used from 2012–2018 regarding entities forming part of corporate groups, and panel regression models with fixed effects were applied. According to the results of the research, domestic corporations are generally more leveraged and have a lower effective tax rate than multinational corporations. At the same time, the effective tax rate was significant only in six models out of sixteen, and mostly in the case of multinational corporations. The direction of impact was inhomogeneous. Other determinants of the financing structure which most often appeared as significant, in the case of companies operating both within domestic and international capital groups, include sales profitability as well as the tangibility and the age of the company. An additional analysis made for Poland and Slovakia determined that a change in the law on thin capitalization influenced entities’ capital structure determinants, but had no significant impact on the companies’ level of debt.
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Ardashev, Artem. "Tax regulation of multinational corporations: development trends in the Russian Federation." Налоги и налогообложение, no. 4 (April 2021): 1–8. http://dx.doi.org/10.7256/2454-065x.2021.4.31013.
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The question of tax regulation of multinational corporations is quite topical. This article analyzes some aspects of tax regulation of multinational corporations in Russia, as well as outlines promising vectors of the development of tax regulation of multinational corporations, taking into account the practice and results of the analysis of information sources suggested for using within the framework of the method of comparable market prices, and correlation between the account statements indicators of independent Russian trade companies. Substantiation is given to the accounting for certain types of other income and expenditures, as well as the need for the implementation of “safe harbor” for transactions with intangible assets. The author offers an alternative for calculating the boundaries of “safe harbor”. In the course of writing this article, the author observed the practice of enforcement of rules that regulate the formation of taxation bases, carried out statistical analysis, and used general logical methods. The conclusion is made that the development of regulation of multinational corporations is a promising direction, as these economic entities generate significant financial flows. The variety of operational models and organization techniques complicate the development of the universal global approach, which consists in distribution of financial results between the accepting countries. Elimination of ambiguity in tax relations is an important vector of development. The article offers the solutions to this problem.
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Singh, Manoj Kumar. "Taxation of Digital Economy: An Indian Perspective." Intertax 45, Issue 6/7 (June 1, 2017): 467–81. http://dx.doi.org/10.54648/taxi2017039.
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The concepts of taxation, essentially important to any governmental set-up, have been modified over time to suit the rapid changes in the economic system. One such example which could be taken here is that of multinational corporations (MNCs) or business entities operating in several tax jurisdictions. Their income and activities being based in multiple jurisdictions may be liable to tax in all of them but, to adhere to the principles of clarity in law and avoidance of double taxation, various concepts emerged, like that of the Permanent Establishment (PE). Such concepts aim at not only bringing predictability for the taxpayer but to balance the conflicting interests of, mostly, the developed nations and the developing nations. In addition to this, certain jurisdictions provide various tax concessions and benefits which can be manipulated by the tax payers so as to have income rendered untaxed Internet advertising is rapidly growing both in terms of revenue and share in the total advertising market. The volume of internet advertising reached USD 135.4 billion in 2014. The market for internet advertising is projected to grow at a rate of 12.1% per year during the period 2014 to 2019. As the stakes started rocketing, taxing such virtual transactions attained prominence. The existing provisions of the income-tax statute were unable to tie the noose around these transactions. Perhaps the reason is Indian income-tax legislation is still governed by physical presence test. The search for new basis of taxation became inevitable. The question was whether the tax should be on consumption or income? Through the Union budget 2016, the government has put forth a proposal to impose an equalization levy at the rate of 6%. This levy is only on B2B Transactions. The author has discussed the features of the proposed equalization levy as per the Committee and the lacunae in the proposed levy will be looked into. In the course of this article, the author seeks to briefly study the dimensions of digital economy and the problems so faced by the taxation regimes. Various recommendations have emerged from academicians and experts, the most prominent of them being the OECD/G20 Base Erosion and Profit Shifting Project, Action 1: 2015 Report (hereinafter referred to as ‘BEPS Report on Action 1’). The models so proposed under will be studied to understand the limitations. Further, in light of the ‘Equalization Levy’ so proposed by the Union Budget, 2016, the stance of the Indian government will be examined keeping in mind the observations of the Report of the Committee on Taxation of E-Commerce3 released in February 2016 (hereinafter referred to as ‘Indian Committee’). However, the author will not dwell into the issues of compliance and infrastructural requirements for each of the proposed solutions, including the one proposed to be adopted by the Indian Government. The scope is further restricted to taxation on income rather than Value Added Tax (VAT).
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Jacobs, Otto H., and Otto H. Jacobs. "The Financing and Taxation of Corporations - A Comparing Analysis for the EC-Member Countries Germany, France and Great Britain." Intertax 21, Issue 1 (January 1, 1993): 4–15. http://dx.doi.org/10.54648/taxi1993002.
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Gupta, Sanjay, and Mary Ann Hofmann. "The Effect of State Income Tax Apportionment and Tax Incentives on New Capital Expenditures." Journal of the American Taxation Association 25, s-1 (January 1, 2003): 1–25. http://dx.doi.org/10.2308/jata.2003.25.s-1.1.
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This study examines how variations in states' corporate income tax regimes affect new capital investment by business. Using U.S. state-aggregated data from 1983 to 1996, we find in pooled and fixed-effects regressions that new capital expenditures by corporations in the manufacturing sector are decreasing in the income tax burden on property (measured as the product of the statutory tax rate and the property factor weight), and increasing at a decreasing rate in investment-related tax incentives. The effect of the income tax burden on property is more pronounced for states mandating unitary taxation or the throwback rule. Triangulating our empirical findings with prior analytical and simulation studies suggests the following hierarchy for the relative importance of major attributes of state corporate income tax regimes: the unitary or throwback requirement is most influential on incremental capital investment, followed by apportionment weights and tax rates, and, finally, investment-related incentives.
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Katz, Irwin J. (Jay). "Instilling Subpart F with Horizontal Equity as Applicable to Individual U.S. Shareholders." ATA Journal of Legal Tax Research 18, no. 1 (November 27, 2019): 1–18. http://dx.doi.org/10.2308/jltr-19-003.
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ABSTRACT Subpart F of the Internal Revenue Code is a body of anti-abuse provisions designed to prevent U.S. shareholders from avoiding tax on the earnings (Subpart F income) generated by foreign corporations they control. Overall, its provisions lack the tax principle of horizontal equity based on tax neutrality. This article will expose the lack of horizontal equity, as applied to individual (not corporate) U.S. shareholders, by being both over-inclusive and under-inclusive. It is over-inclusive in imposing punitive tax consequences when tax avoidance is unachievable, including the taxation of GILTI, a new type of Subpart F income. It is under-inclusive because tax avoidance is achievable by taking advantage of certain loopholes in Subpart F. Using IRC §469 (that successfully eliminated tax shelters) as a model, this article recommends revisions to relevant Subpart F provisions that will eliminate tax avoidance without punitive tax consequences and also foreclose potential tax avoidance opportunities.
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Zinn, Benedikt. "Non-profit Taxation on Corporations in the EU: Lessons from Corporate Tax Reforms in Germany and Tax Implications of the Global Economic Crisis." Intertax 39, Issue 10 (October 1, 2011): 494–520. http://dx.doi.org/10.54648/taxi2011052.
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Without any doubt, one of the primary policy issues in public finance in the European Union (EU) is the issue of tax competition, which results in a race to the bottom in statutory tax rates, tax base broadening policies, and potential distortions in firm decisions. The literature focuses mainly on profit taxes; however, as the financial crisis is biting into the real economy, non-profit taxes have become a more important factor in the overall tax burden on companies. In this context, one important question is whether non-profit taxation and tax base broadening policies have accelerated the course of economic downturn. This article analyses the impact of non-profit taxes on the overall tax burdens of companies. It offers not only a broad geographical scope but also great detail in calculations of tax burdens on income-independent taxes. In particular, it reveals that tax regimes characterized by restrictive thin capitalization rules, tightened loss offset rules, or a high proportion of non-profit taxes in the overall tax mix are more severely hit by economic downturns. The various tax measures taken by many EU-27 Member States in response to the crisis are, therefore, looked upon favourably.
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Goodspeed, Timothy J. "Some Simple Analytics of the Taxation of Banks as Corporations: Effects on Loans and Systemic Risk, Deposits, and Borrowing." National Tax Journal 70, no. 3 (September 1, 2017): 643–72. http://dx.doi.org/10.17310/ntj.2017.3.05.
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Eriksson, Martin. "Embedding Big Business. The Political Economy of the 1938 Corporate Tax Reform in Sweden." Enterprise & Society 15, no. 2 (February 12, 2014): 285–306. http://dx.doi.org/10.1093/es/khu003.
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This article examines the business–government relations during the policy and decision-making processes that preceded the 1938 corporate tax reform in Sweden. This reform involved creating a new tax system under the turbulent economic conditions of the interwar period. But while literature on tax history has found that such circumstances often disable actors from agreeing on tax policies, a constructive outcome was still reached in the Swedish case. In this regard, it is demonstrated that one crucial factor behind the creation of the 1938 corporate tax reform was the formation of a coalition between the Social Democratic party and the business peak associations around a number of areas where their taxation interests coincided. Here, the Social Democrats agreed to shelter profits from corporations as long as they were managed according to the intentions of their countercyclical economic policy that encouraged industrial investments and employment expansion.
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Vlasova, O. "TRANSFER PRICES: PREREQUISITES FOR USE IN MANAGEMENT ACCOUNTING AND TAX ADMINISTRATION." Series: Economic science 2, no. 162 (March 26, 2021): 71–77. http://dx.doi.org/10.33042/2522-1809-2021-2-162-71-77.
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Today, the issues of transfer pricing come to the fore in the ranking of current problems of tax administration not only in Ukraine but also in the world as a whole. This is due to the need for tax control to ensure price equality between related and independent entities in international business as a measure to combat the erosion of the tax base and the withdrawal of profits from taxation. The article presents a structured analysis of research by foreign and domestic scientists on transfer pricing in the field of management accounting or tax control. In particular, the grouping of views of scientists and practitioners on the nature and role in the accounting and analytical system of transfer pricing from the point of view of management accounting and tax administration. Study of the impact on the practice of transfer pricing methods of the picture of economic reality distorted by the negative impact of the COVID-19 pandemic. The need to use the transfer pricing mechanism in management accounting is due to the current trend of decentralization of management, and a prerequisite - the desire of top management to accelerate the production process, accelerate the turnover of equity and maximize profits. The advantages of using transfer pricing in management accounting to accelerate the production process and maximize profits, which led to the creation of corporations with the final technological cycle. It is also established that when deciding on the use of such a tool of internal pricing, one should keep in mind the cautions analyzed in the article. The preconditions for the introduction of tax control over transfer pricing in international business, as well as the basic laws and regulations in force in the global and Ukrainian economic space. The necessity and validity of the application of the OECD International Guidelines on Transfer Pricing, despite the provisions of Art. 39 of the Tax Code of Ukraine The ways of further development of tax control over transfer pricing within the framework of the BEPS Action Plan in Ukraine are considered. The need for further research on solving the problems of transfer pricing in the field of management accounting and taxation was identified, especially on the preparation of an information basis to justify the compliance of transfer prices with «Arm’s length principle».
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A. Tsindeliani, Imeda, Karina T. Anisina, Elena V. Migacheva, Olga I. Lyutova, and Lyudmila Lesina. "Current Trends in Counteracting Thin (Insufficient) Capitalization in the Russian Legal System." Intertax 49, Issue 8/9 (August 1, 2021): 713–24. http://dx.doi.org/10.54648/taxi2021070.
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The purpose of this study is to theoretically substantiate the stages of development of judicial approaches to the application of thin (insufficient) capitalization rules in the tax relations of Russian taxpayers with foreign companies, including transnational corporations, operating in Russia. The development of legal regulation and the corresponding judicial approaches regarding thin (insufficient) capitalization is retrospectively considered. In particular, the possibility of applying this rule, provided double taxation avoidance, was studied as well as its correlation with the application of other anti-evasive norms of tax law in Russia. In addition, the following was performed: (1) periodization of the stages of judicial practice development on the application of thin (insufficient) capitalization rules by Russian courts; (2) formulation of new approaches contained in the Decision of the Supreme Court of the Russian Federation dated 14 September 2020 in case No. A60-29234/2019 (Mega-Invest Limited liability company (LLC)). The practical significance of this article consists of proposals for eliminating the inadequacies of judicial practice in the aspect of thin capitalization as well as a recommendation to take into account the direction of development of such judicial practice in the preparation of tax regulatory acts and to prevent illegal methods of tax minimization. Tax relations, taxpayer, judicial practice, interest rate, dividends.
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Kohlhase, Saskia, and Jochen Pierk. "The effect of a worldwide tax system on tax management of foreign subsidiaries." Journal of International Business Studies 51, no. 8 (December 2, 2019): 1312–30. http://dx.doi.org/10.1057/s41267-019-00287-9.
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AbstractUnder a worldwide tax system, firms pay taxes on their domestic income and repatriated foreign income, whereas under a territorial tax system repatriated foreign income is exempt from taxation. We examine whether worldwide tax systems reduce the incentives of multinational corporations to engage in tax management in their foreign subsidiaries. Using two quasi-natural experiments, we show that multinationals lower the effective tax rates in their foreign subsidiaries after countries switch from a worldwide to a territorial tax system. Thus, multinationals subject to a worldwide tax system face competitive disadvantages compared to competitors from countries with a territorial tax system.
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Bronzewska, Katarzyna, and Filip Majdowski. "Revolutionary Changes to the Arms Length Principle under the OECD BEPS Project: Have CFC Rules Become Redundant?" Intertax 46, Issue 3 (March 1, 2018): 210–24. http://dx.doi.org/10.54648/taxi2018023.
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Title question of the article is deliberately provocative. The subject of interactions between Controlled Foreign Company (CFC) regulations and transfer pricing (TP) regulations is a complex topic that has been bringing divergent opinions over many decades (In United States, from where both CFC regime and TP regime originated, the literature on this subject has been present at least since 1969, being no more than one year after the introduction of detailed US TP regulations (1968). CFC regulations – Subpart F – was introduced therein in 1962. See for instance: L. Kauder, Taxation of Domestically Controlled Foreign Corporations: A Comparative Study of Subpart F and Section 482, 14(2) Villanova L. Rev. (1969)). The polemic in this regard has, however, acquired a new dimension together with the OECD’s adoption of modifications to the arm’s length principle as referred to in Article 9 of the OECD Model Convention under the Base Erosion and Profit Shifting (BEPS) project, which led to publishing the 2017 TP Guidelines for Multinational Enterprises and Tax Administration (OECD, 2017 TP Guidelines for Multinational Enterprises and Tax Administration, available at http://www.oecd.org/tax/transfer-pricing/oecdtransfer- pricing-guidelines-for-multinational-enterprises-and-tax-administrations-20769717.htm). These amendments, which involve the expansion of the guidelines on the relationship between (1) the legal title to the asset, and (2) the eligibility of a cross-border group of related entities to recognize the corresponding income generated by that asset, has led to an unobservable earlier approximation of the scope of CFC and TP regimes. It is therefore the study question of this article to verify whether the enhanced TP regulations are capable of replacing CFC regulations.
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Blum, Daniel W. "Controlled Foreign Companies: Selected Policy Issues or the Missing Elements of BEPS Action 3 and the Anti-Tax Avoidance Directive." Intertax 46, Issue 4 (April 1, 2018): 296–312. http://dx.doi.org/10.54648/taxi2018031.
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The discussion of controlled foreign corporations (CFCs) in both the Final Report on Action 3 of the OECD’s Base Erosion and Profit Shifting Project and the Anti-Tax Avoidance Directive (ATAD) has failed to address some high-level policy questions that are worth considering in more detail. Depending on the scope of the tax system (worldwide vs. territorial) and the means by which double taxation is avoided (credit vs. exemption), the crucial policy questions revolve around the issue as to which tax base should be protected and in which capacity (i.e. as the residence state or the source state). Moreover, the question as to whether deferral and income diversion should be curtailed as a matter of principle or only if the deferred/diverted income is low taxed in the state of residence of the CFC must be answered. On an operational level, the means by which income is included require careful assessment. Depending on whether a CFC regime pierces the CFC’s corporate veil or applies a deemed dividend approach, the interaction with both the relevant distributive rules and – in case of EU Member States – the EU Fundamental Freedoms, potentially limit the scope of a CFC regime. By tracing back the underlying structural tensions inherent in domestic corporate tax laws and highlighting the policy choices that legislators face along the way to enact coherent CFC regimes that counter both tax deferral and income diversion while respecting the existing network of rules governing the allocation of taxing rights in cross-border situations, this article facilitates a principled discussion and, thus, helps to overcome the widespread BEPS fallacy of accepting the technical outcomes of the BEPS project without questioning the underlying principles.
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Das-Gupta, Arindam. "Income Tax Compliance Cost of Corporations in India, 2000–01." Vikalpa: The Journal for Decision Makers 31, no. 4 (October 2006): 9–30. http://dx.doi.org/10.1177/0256090920060402.
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This is the first study of compliance costs of income taxation of corporations in India. Compliance costs are the costs of meeting obligations under the income tax law and in planning to save taxes. Opportunity costs such as when tax refunds are delayed are also included. Social compliance costs, gross versus net private costs, and mandatory versus voluntary cost can be distinguished. Gross private compliance costs include both legal and illegal expenses (such as bribes paid), employee costs, the cost of tax advice, and also other non-labour expenses. Estimates in this paper are for the year 2000-01 based on a postal survey of 45 companies throughout India in August-September 2001. Estimated gross compliance costs, excluding bribe costs, are between 5.6 and 14.5 per cent of corporation tax revenues. These are similar to estimates for other countries near the lower limit but are a cause for concern near the upper limit. Tax deductibility of legal expenses and cash flow benefits from the timing difference between taxable income and payment of tax result in net compliance costs between minus 0.7 and plus 0.6 per cent of corporation tax revenue. Both gross and net compliance costs are regressive. Among other findings, five are noteworthy: First, around 25 per cent of sampled companies knowingly paid excess tax (median value: 46%) since tax evasion penalty cannot be levied under Indian law if assessed taxes have already been paid. Second, 70 per cent of companies, especially small companies, used external assistance to prepare tax returns accounting for 39 per cent of the legal compliance costs. Third, voluntary costs associated with tax planning contribute 19 to 43 per cent of total compliance costs. Fourth, the average sample company had 10 to 11 assessment years locked in disputes for tax or penalty in addition to around two years for which assessments were incomplete. Statistical analysis suggested that one extra disputed assessment year raises legal compliance costs by 5.7 per cent. Fifth, it was found to be fairly common for incorrect application of tax laws by tax officials in areas where they have high discretion to cause tax assessments to be revisited. Among reform suggestions is streamlining of 22 legal and procedural �hot spots� which add to compliance costs. Since the response rate was a disappointing 1.15 per cent, the stratified random sample design degenerated into a convenience sample with over-representation of large firms and under-representation of loss-making and zero-profit companies. Therefore, results should be viewed as preliminary and tentative. Other problems are that there were only qualitative questions about in-house cost components; assumed opportunity cost of funds to value cash flow benefits were used; and, as in earlier studies, there can possibly be a bias due to incorrect apportionment of fixed costs and the value of time of company management
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Marmul, Larisa, Natalia Novak, and Edem Khalilov. "The role of individual income tax administration in managing the competitiveness of agricultural enterprisesvv." University Economic Bulletin, no. 51 (December 21, 2021): 25–32. http://dx.doi.org/10.31470/2306-546x-2021-51-25-32.
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The subject of research is theoretical, methodological and practical aspects of managing the efficiency and competitiveness of agricultural enterprises, taking into account the administration of personal income tax. The purpose of the article is to determine the role of personal income tax administration in managing the competitiveness of agricultural enterprises, identify its problems and justify proposals for their solution. The methodological basis of the article is historical, monographic, system-structural analysis and synthesis, statistical and economic, accounting, problem-target. The results of the article. It is determined that the administration of personal income tax as one of the most important in filling the state budget has a significant impact on the efficiency and competitiveness of agricultural enterprises, especially in terms of the tax rate on wages and other personal income; spending time and money on taxation processes. It was found that its rate of 18,0% on the wage bill is quite rational, but it can be optimized to the world average of 16,1% or less in order to stimulate employment and the formation of the middle class in rural areas. Other problems, which concern rather large (almost 2,0 times more than the world average) expenditures of time and money), should be solved by automating accounting processes, online consultations with tax authorities, internal control over timely payment of taxes. Field of application of results. In educational institutions of higher education, in managing the competitiveness of agricultural enterprises and corporations. Conclusions. The administration of personal income tax is an important factor in shaping the competitiveness of agricultural enterprises and its management. Its impact is directly through the amount or rate of tax; the procedure for its accrual and payment; time and money costs associated with administration. It should be noted that the share of PIT in relation to wages is quite acceptable and, on average, reaches 18,0% at 16,6% of the world average. However, together with the shares of SDRs and military dues, tax accruals increase significantly and exceed the 30% barrier, which is much higher than in the European Union. In general, high wage accruals do not motivate the work of the rural population. This is especially noticeable when rent for land shares is used as a source of passive income. The next problem that needs to be addressed is the significant cost and time spent on PIT administration. It allows automation to solve. Automation of personal income tax accounting is an important part of the automation of management processes and accounting of agricultural enterprises. It provides an opportunity not only to organize the automated workplace of each accountant, but also to improve the work by creating in the accounting department responsible for keeping records of inventory and other resources; labor and wages, taxes; production; product sales.
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Kobylynska, Т. V., and N. Yu Huseva. "A Statistical Study of the Forestry in Ukraine." Statistics of Ukraine 89, no. 2-3 (November 24, 2020): 12–21. http://dx.doi.org/10.31767/su.2-3(89-90)2020.02-03.02.
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The article is devoted to the analysis of the forestry in Ukraine as the reference point for further development of the framework for constructing the national forest account allowing for a description of interactions between economic activities and forests as a nature environment, and for consistent and comprehensive integration of environmental and economic problems in this field. The study covers the existing statistical definitions, classifications and the available statistical information about the forest, selected forestry indicators for Ukraine, the existing sources of data for the analysis of forestry, with proposing the necessary steps for further applications of forest accounting tools, in order to construct the forest account.
It is pointed out that the forestry is represented by two large groups of institutional units: physical persons or groups of physical persons in form of households; legal entities, established and operated in keeping with the law, irrespective of what persons or entities may be their owners or managers. The main categories of legal entities are corporations, non-commercial organizations, and public administration bodies.
It is determined that the main sources of data about the forest fund and forest resources of Ukraine are as follows: (i) statistical information based on the data from enterprises, obtained from official statistical observations of the State Statistics Service of Ukraine; (ii) administrative data based on the data from enterprises, obtained by public administration bodies (The State Service of Ukraine on Geodesy, Cartography and Cadastre, the State Agency of Forest Resources of Ukraine, the State Custom Service, the State Taxation Service) as part of functional responsibilities; (iii) the data of the national inventory of forests, obtained by the authorized bodies. The latest official data of the national forest inventory for Ukraine are available as of January 01, 2011, but these data have not been published yet in a proper manner.
It is demonstrated that the official statistics cover a limited set of statistical data about the forestry due to the institutional constraints. A dynamic and structural analysis of the forest lands is explored, with outlining the main problems related with improving methodological approaches to the formation of the forestry statistics. The analysis allowed for determining the main areas of improvements in the forestry accounting and coming up with propositions of necessary steps to solve the problems of statistical studies of this industry.
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Kobylynska, Т. V., and N. Yu Huseva. "A Statistical Study of the Forestry in Ukraine." Statistics of Ukraine 89, no. 2-3 (November 24, 2020): 12–21. http://dx.doi.org/10.31767/su.2-3(89-90)2020.02-03.02.
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The article is devoted to the analysis of the forestry in Ukraine as the reference point for further development of the framework for constructing the national forest account allowing for a description of interactions between economic activities and forests as a nature environment, and for consistent and comprehensive integration of environmental and economic problems in this field. The study covers the existing statistical definitions, classifications and the available statistical information about the forest, selected forestry indicators for Ukraine, the existing sources of data for the analysis of forestry, with proposing the necessary steps for further applications of forest accounting tools, in order to construct the forest account.
It is pointed out that the forestry is represented by two large groups of institutional units: physical persons or groups of physical persons in form of households; legal entities, established and operated in keeping with the law, irrespective of what persons or entities may be their owners or managers. The main categories of legal entities are corporations, non-commercial organizations, and public administration bodies.
It is determined that the main sources of data about the forest fund and forest resources of Ukraine are as follows: (i) statistical information based on the data from enterprises, obtained from official statistical observations of the State Statistics Service of Ukraine; (ii) administrative data based on the data from enterprises, obtained by public administration bodies (The State Service of Ukraine on Geodesy, Cartography and Cadastre, the State Agency of Forest Resources of Ukraine, the State Custom Service, the State Taxation Service) as part of functional responsibilities; (iii) the data of the national inventory of forests, obtained by the authorized bodies. The latest official data of the national forest inventory for Ukraine are available as of January 01, 2011, but these data have not been published yet in a proper manner.
It is demonstrated that the official statistics cover a limited set of statistical data about the forestry due to the institutional constraints. A dynamic and structural analysis of the forest lands is explored, with outlining the main problems related with improving methodological approaches to the formation of the forestry statistics. The analysis allowed for determining the main areas of improvements in the forestry accounting and coming up with propositions of necessary steps to solve the problems of statistical studies of this industry.
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Davis, Ann Boyd, and Amy M. Hageman. "An Exploration of State Income Tax Nexus: Does Economic Nexus Really Benefit States?" Journal of the American Taxation Association 36, no. 1 (August 1, 2013): 105–35. http://dx.doi.org/10.2308/atax-50602.
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ABSTRACT While considerable attention in the state taxation literature has been devoted to understanding how much of a corporation's income is subject to tax in a state, much less has been placed on understanding the more critical question of whether a corporation is subject to tax in a given state in the first place (Wildasin 2010). This study investigates the antecedents of state income tax nexus and the influence of economic nexus adoption on state corporate tax revenue collections with a two-stage least squares model using an instrumental variable approach and panel data from 2000–2009. The results of this model indicate that adoptions of economic nexus standards are more common in states with a weaker domiciled business group presence, consistent with interest group theory; adoptions are also more common among states with no required combined reporting, no NOL carryback provisions, the imposition of an alternative minimum tax (AMT), and a higher gross state product. Interestingly, after the first year of adoption, states that adopt economic nexus standards have no statistically significant difference in corporate tax revenue collections compared to those that follow a physical presence standard. In additional analyses, we determine that the interactive influences between diffusion and political factors and between diffusion and interest group factors also affect states' economic nexus adoptions. These results contribute to the taxation literature by suggesting that states' economic nexus standard adoptions are carried out for interest group, political, and regional diffusion reasons, and are not associated with any long-term discernible effects on state corporate taxation revenues. Data Availability: The data used in this study are available from public sources identified in the text and Table 2.
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Kosіak, Myroslav, and Inna Kosіak. "Blockchain technologies and their application in governmentadministration." Problems of Innovation and Investment Development, no. 19 (April 2019): 182–90. http://dx.doi.org/10.33813/2224-1213.19.2019.15.
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The purpose of the article. The article considers the Blockchain technology asan innovative tool. In particular, the essence and background of the developmentof blocks, the principles and specifics of the functioning of the system, as well asthe scheme of its work, are determined. The article presents the prospects forusingdistributed registry technologies (blockchain) in various socioeconomic spheresrelated to state administration. Provided examples and forecasts of the use ofblockchain technologies in the provision of state and municipal services forindividuals and legal entities in the following areas: formation of a unified registercontaining the history of the placement of the state, municipal order, as well asprocurement of corporations with state participation and / or control; registers ofdocuments (diplomas, certificates, lost and disavowed passports, policies for movableand immovable property insurance, health, etc.); database of court decisions andexecutive proceedings; public participation portals for citizens of Ukraine district- city – country. The fact that the blockchain technology is, first of all, theprinciples, and not the only possible way of implementing them, allows us to counton maximum openness and multivariate application in a dynamically changingchanging«digital world». Methodology. The research methodology is to use a combinationof methods: analytical, historical, comparative. The scientific novelty. The priorityof state blockchain systems introduction in stationary and distant voting, distributeddocument circulation, medical data registration, land resources registration,electronic auctions (auctions) in Ukraine was grounded. Conclusions. Already today,blockchain systems can change the role and participation of citizens in the conductof the state-management process, by raising the responsibility level, from thetransparent will expression in the elections to regulating the government serviceactivity in the society’s digitization conditions. The main advantages blockchainsystems using by public authorities that will increase the level of citizens trust todigital technologies using in general, namely: reliability and reliability of datastorage, transparency of transactions and virtually absolute protection of informationfrom distortion and unauthorized removal (relocation), are determined. In furtherscientific research it is proposed to consider the promising areas of the blockchaindigital technology usage: service activities of public authorities, legal proceedings,property rights management, implementation of migration control, verification ofgoods and services, registration of data on passing qualifying tests, patenting,intellectual property, digital identification, logistics , taxation, accounting ofbudget funds movement.
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Branston, J. Robert, and Anna B. Gilmore. "The failure of the UK to tax adequately tobacco company profits." Journal of Public Health 42, no. 1 (February 6, 2019): 69–76. http://dx.doi.org/10.1093/pubmed/fdz004.
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Abstract Background A key driver of the global tobacco epidemic is the massive profit earned from manufacturing tobacco products despite high levels of product taxation. Two of the four major Transnational Tobacco companies are based in the UK, where there is growing evidence of corporate tax avoidance by transnational firms and where there are calls for the industry to pay more towards the harms caused by tobacco products. Objectives/Methods UK tobacco company profit and corporation tax data between 2009 and 2016 is obtained from publically available sources. The intention is not to perform a piece of forensic accounting but to establish the broad pattern of profit and taxation in order to inform consideration of tobacco product and firm taxation, and hence public health. Results Very little profit based taxation has been paid in the UK despite high levels of reported profits, both in the domestic market and globally. Conclusions The UK needs better reporting and corporate taxation standards. Tobacco companies should be made to pay more profit based taxation, such as by extending the surcharge on corporation tax currently paid by UK banks, and by making sure companies pay appropriate taxes when reorganizing corporate structures.
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de Graaf, Arnaud, and Paul de Haan. "Fundamental Change in Countries Corporate Tax Framework Needed to Properly Address BEPS." Intertax 42, Issue 5 (May 1, 2014): 306–16. http://dx.doi.org/10.54648/taxi2014032.
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Traditionally, countries impose their corporation tax on an entity-by-entity rather than a group-wide basis. As the taxability of entities, tax bases, and tax rates vary from one country to another, these differences give rise to mismatches, leading to double taxation, but also to non- or almost nontaxation. In practice, however, the overall operation of the countries' divergent corporation tax systems seems to allow MNCs to reduce their overall tax burden by entering into strategic 'Base Erosion and Profit Shifting' operations. In its February 2013 report, the OECD suggests developing a global and comprehensive action plan to provide solutions for realigning international taxation standards with the current global business environment. In its follow-up report of July 2013, the OECD identifies fifteen specific actions. It, however, advocates continuing to maintain the current building blocks of international taxation, including the separate entity approach and the arm's length principle. The question arises whether such an approach would address the issue of BEPS effectively. Another issue is that this will not result in MNCs' profits being fairly allocated between states, given that measures to counter hybrid mismatch arrangements and to strengthen CFC rules mean that an MNCs' residual profit will be attributed to the state in which its top holding company is resident.
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Englisch, Joachim. "Taxation of Cross-Border Dividends and EC Fundamental Freedoms." Intertax 38, Issue 4 (April 1, 2010): 197–221. http://dx.doi.org/10.54648/taxi2010025.
Full textAbstract:
The very first direct tax case scrutinized by the European Court of Justice (ECJ) by applying the EC fundamental freedoms concerned dividend taxation. Ever since, most of the fundamental questions related to the scope of the fundamental freedoms and their relationship to aspects of the Member States’ fiscal sovereignty have crystallized in the field of dividend taxation. To be mentioned in particular: Developing criteria for comparability of situations, supranational versus national approach in assessing a discrimination/restriction, fiscal cohesion, balanced allocation of taxing rights and international double taxation, relationship between freedom of establishment and free capital movement in third-country cases. Thus, the dividend tax cases of the ECJ have not only exerted great influence on the shape of Member States’ corporation tax systems; they have also contributed substantially to the Court’s understanding of the interaction between fundamental freedoms and non-harmonized national tax law. The now abundant case law therefore merits a critical review regarding its coherence, the underlying conceptions of the scope and thrust of European Union fundamental freedoms, and the fundamental issue of how to reconcile them with core principles of fair and balanced taxation in an imperfect internal market.
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Wildasin, David E. "State Corporation Income Taxation: An Economic Perspective on Nexus." National Tax Journal 63, no. 4, Part 2 (December 2010): 903–24. http://dx.doi.org/10.17310/ntj.2010.4s.04.
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