Academic literature on the topic 'Formulary taxation'

The possible ways of corporate tax base harmonization in the European Union are presented in the paper. Present situation when there are 27 different taxation systems used in the EU increases compliance costs of taxation to the companies and therefore decreases their competitiveness. It was proved, that there is negative correlation between the size of the company and the size of the compliance costs of taxation. Based on that, the European Commission has decided for twin-track strategy – to introduce home state taxation in the short term and common consolidated corporate tax base in the long term. In respect to the fact, that the pilot project in the frame of home state taxation system has not started yet, the attention has been turned to the common consolidated corporate tax base. The paper discusses the possible attitudes and methods of consolidated tax base allocation. Based on mentioned arguments the formulary apportionment with factors which generate the taxable income of the group (assets, payroll, turnover, etc.) seems to be the best solution. Factors and their weight should become the subject of further discussion in the European Union. The aim of the paper is to present the possible harmonization models and further to discuss the methods which could be used for allocation of the consolidated tax base under CCCTB.

The subject of the research is mineral extraction tax evolution as the main rental payment in mineral resources sector.The purposesof the work are to determine the role of the mineral extraction tax in the current taxation system, assessment of its influence on the extracting industries development, studying key problems in taxation methodology and policy, proposals on the development of mineral extraction tax mechanisms submission. The author analyses the tax current state, compliance to the criteria of economic efficiency and principles of taxation, the reforming of the mineral extraction tax and the newest trends in the sphere are assessed.The author emphasizes scientific basis for oil metering perfection, correlation between metrological and economic aspects of this metering, assessment of influence of systemic approach to the raw materials transported by oil-trunk pipelines quality.The author also analyses special tax relieves in mineral extraction taxation and their influence on the budget revenue, considers the unsolved problems of cost of extracted solid minerals and tax incentives for import substitution of some minerals basing on the public statistics, tax statistics, forecasts for social economic development and the main directions of budget, tax and customs policies. The research resulted in arguments for the necessity of transition to specific tax rates for solid mineral extraction taxation that should be adjusted taking into consideration some factors that are used for tax differentiation in taxation of hydrocarbon extraction; also conceptual features of reliable inventory-making for hydrocarbons have been developed; an assessment of special tax relieves in mineral extraction taxation is given. It is concluded that application of the rated method of calculating taxation base in mineral extraction taxation is economically meaningless as the real value of the extracted materials is not taken into account. Taxation base for mineral extraction must be defined not as value, but as the amount of the extracted mineral, and tax rate should be defined according a proposed formular.

Several khipus—Inka knotted-string recording devices—were recently excavated at a storage facility at the Peruvian south coast site of Inkawasi, found buried under agricultural produce (i.e., chili peppers, peanuts, and black beans). These khipus contain a formulaic arrangement of numerical values not encountered on khipus from elsewhere in Tawantinsuyu (the Inka Empire). The formula includes first, a large number, hypothesized to record the sum total of produce included in a deposit, followed by a “fixed number,” and then one or more additional numbers. The fixed number plus the additional number(s) sum to the original large number. It is hypothesized that the fixed number represents an amount deducted from the deposit to support storage facility personnel. As such, it represented a tax assessed on deposits, the first evidence we have for a system of taxation on goods in the Inka Empire. It is proposed that the size and complexity of the storage facility at Inkawasi prompted the “invention” of a kind of financing instrument—taxation—not known previously from Inka administration. We also consider, but provisionally set aside, the alternative hypothesis that the fixed values recorded on the Inkawasi khipus could have represented amounts of seeds set aside from deposits for the next year's planting.

Abstract Discussion of corporate tax reform loosely uses concepts like “value creation” and “economic substance” as a basis for systematic departures from the tax outcomes that would otherwise eventuate from computational artifacts based on price, but in fact mainstream economics does not have a theory of value creation as distinct from computational artifacts based on price. Corporate tax reform discourse is therefore an unacknowledged exercise in heterodox value theory. This article deploys global value chain theory to question a key assumption in that exercise; the assumption that while intra-group pricing may be modified or ignored for the purposes of reallocating the corporate tax base between jurisdictions for corporate tax purposes, prices arrived at between entities not under common control are sacrosanct. The article proceeds to deploy an expanded version of the global value chain analytic, the “global inequality chain”, to (i) investigate this question using a schematic illustrative case study based around Amazon’s UK/Luxembourg structuring, and (ii) to develop the beginnings of a concept of “unitary taxation by formulary apportionment of the entire value chain”, which would enable unfettered “diagonal” re-allocations across the space which the global inequality chain describes.

The ever-increasing digitalization of businesses has accelerated the need to address the many shortcomings and unresolved issues within the international corporate income tax system. In particular, the customer or “user”—through their online activities—is now considered by many as being a critical driving force behind the value of digital services. Furthermore, the rapid growth of digital service providers over the last decade has made them an increasingly popular target for special taxes—similar to wealth and solidarity taxes—which can also help mobilize much-needed revenues in the wake of a crisis. This paper argues that a plausible conceptual case can be made to tax the value generated by users under the corporate income tax. However, a number of issues need to be tackled for user-based tax measures to become a reality, which include agreement among countries on whether user value justifies a reallocation of taxing rights, establishing the legal right to tax income derived from user value, as well as an appropriate metric for valuing user-generated data if it is ever to be used as a tax base. Furthermore, attempting to tax only certain types of business is ill-advised, especially as user data is now being exploited widely enough for it to be recognized as an input for almost all businesses. Several options present themselves for consideration—from a modified permanent establishment definition combined with taxation by formulary apportionment, to user-based royalty-type taxes—each with their own merits and misdemeanors.

Abstract Notwithstanding its political dimension, international tax avoidance is also the result of a regulatory process that makes reference to overarching concepts and representations. The current debate is featured by two overarching principles of ‘negative’ and ‘positive’ taxation under the law: the one arguing for the right to minimise the tax payment, the other one for the duty to pay a fair tax amount. This debate is further featured by two distinctive approaches to tax base determination: the market basis coupled with the legal person basis, and the economic substance basis. The economic substance approach argues that the received approach grapples with economic reality featured by integrated transnational corporate groups. These groups operate across jurisdictions and have the capacity to reshape their legal-economic structuring to obtain specific tax results. An adequate response urges then to consider these groups through consolidated report (unitary approach), allocating their consolidated result to involved jurisdictions through formulary apportionment. This unitary approach is upheld by recent advances by the theory of the firm as enterprise entity, which combines law and economics with accounting. The business firm is then understood as a specific economic coordination backed by its institutional structure of production, including its accounting system. This theoretical consistency is appealing and deserves further investigation, including to foster cross-fertilisation and harmonisation of financial and tax accounting systems. But it does not imply a straightforward claim to adopt current international accounting standards for tax purposes. International accounting standards-making has been formally disconnected by national jurisdictions, it currently excludes public policy concerns, and it may be substantially unable to avoid the very same ‘specifications’ on the letter of the law that have been already paving the way to loopholes and structuring opportunities in tax regulation.

The Formulary Approach to the Taxation of Transnational Corporations: A Realistic Alternative? Synopsis The central hypotheses of this thesis are: that global formulary apportionment is the most appropriate method for the taxation of transnational corporations (TNCs) in lieu of the present system commonly referred to as the separate accounting/arm's length method; and that it is essential, in order to implement the proposed global formulary model, to create an international organisation which would fulfil, in the taxation field, a role equivalent to that of the World Trade Organisation (WTO) in international trade. The world economy is fast integrating and is increasingly dominated by the activities of transnational enterprises. These activities create a dual tax problem for various revenue authorities seeking to tax gains derived thereon: Firstly, when two or more countries entertain conflicting tax claims on the same base, there arises what is commonly referred to as a double taxation problem. Secondly, an allocation problem arises when different jurisdictions seek to determine the quantum of the gains to be allocated to each jurisdiction for taxation purposes. The traditional regime for solving both the double taxation and the allocation problem is enshrined in a series of bilateral treaties signed between various nations. These are, in general, based on the Organisation for Economic Co-operation and Development (OECD) Model Treaty.1 It is submitted, in this thesis, that while highly successful in an environment characterised by the coexistence of various national taxation systems, the traditional regime lacks the essential attributes suitable to the emerging 'borderless world'. The central theme of this thesis is the allocation problem. The OECD Model attempts to deal with this issue on a bilateral basis. Currently, the allocation problem is resolved through the application of Articles 7 and 9 of the OECD Model. In both instances the solution is based on the 'separate enterprise' standard, also known as the separate entity theory. This separate accounts/arm's length system was articulated in the 1930s when international trade consisted of flows of raw materials and other natural products as well as flows of finished manufactured goods. Such trade is highly visible and may be adequately valued both at the port of departure or at the port of entry in a country. It follows that within this particular system of international trade the application of the arm's length principle was relatively easy and proved to be extremely important in resolving both the double taxation and apportionment problems. Today, however, the conditions under which international trade is conducted are substantially different from those that prevailed until the 1960s. * Firstly, apart from the significant increase in the volume of traditionally traded goods, trade in services now forms the bulk of international exchanges. In addition, the advent of the information age has dramatically increased the importance of specialised information whose value is notoriously difficult to ascertain for taxation purposes. * Secondly, the globalisation phenomenon which gathered momentum over the last two decades has enabled existing TNCs to extend their global operations and has favoured the emergence of new transnational firms. Thus, intra-firm trade conducted outside market conditions accounts for a substantial part of international trade. * Thirdly, further economic integration has been achieved following the end of the Cold War and the acceleration of the globalisation phenomenon. In this new world economic order only TNCs have the necessary resources to take advantage of emerging opportunities. The very essence of a TNC is 'its ability to achieve higher revenues (or lower costs) from its different subsidiaries as a whole compared to the results that would be achieved under separate management on an arm's length basis.'2 Yet, the prevailing system for the taxation of TNCs overlooks this critical characteristic and is therefore incapable of fully capturing, for taxation purposes, the aggregate gains of TNCs. The potential revenue loss arising from the inability of the present system to account for and to allocate synergy gains is substantial. It follows that the perennial questions of international taxation can no longer be addressed within the constraints of the separate entity theory and a narrow definition of national sovereignty. Indeed, in order to mirror the developments occurring in the economic field, taxation needs to move from a national to an international level. Moreover, a profound reform of the system is imperative in order to avoid harmful tax competition between nations and enhance compliance from TNCs. Such a new international tax system needs to satisfy the test of simplicity, equity, efficiency, and administrative ease. To achieve these objectives international cooperation is essential. The hallmark of international cooperation has been the emergence, after World War II, of a range of international organisations designed to facilitate the achievement of certain goals deemed essential by various nations. The need for an organisation to deal specifically with taxation matters is now overwhelming. Consequently, this thesis recommends the creation of an international organisation to administer the proposed system. The main objective of this international organisation would be to initiate and coordinate the multilateral application of a formulary apportionment system which, it is suggested, would deal in a more realistic way with 'the difficult problems of determining the tax base and allocating it appropriately between jurisdictions'.3 The global formulary apportionment methodology is derived from the unitary entity theory. The unitary theory considers a TNC as a single business which, for convenience, is divided into 'purely formal, separately-incorporated subsidiaries'.4 Under the unitary theory the global income of TNCs needs to be computed, then such income is apportioned between the various component parts of the enterprise by way of a formula which reflects the economic contribution of each part to the derivation of profits. The question that arises is whether the world of international taxation is ready for such a paradigm shift. It is arguable that this shift has already occurred albeit cautiously and in very subtle ways. Thus, the latest of the OECD Guidelines on the transfer pricing question provides that 'MNE [Multinational Enterprise] groups retain the freedom to apply methods not described in this Report to establish prices provided those prices satisfy the arm's length principle in accordance with these Guidelines.'5 Arguably, the globalisation process has created 'the specific situation' allowed for by the OECD. This thesis, therefore, explores the relative obsolescence of the bilateral approach to the taxation of TNCs and then suggests that a multilateral system is better adapted to the emerging globalised economy. The fundamental building blocks of the model proposed in this thesis are the following: * First, the administration and coordination of the proposed system is to be achieved by the creation of a specialised tax organisation, called Intertax, to which member countries would devolve a limited part of their fiscal sovereignty. * Second, in order to enable the centralised calculation of TNC's profits, the proposed system requires the formulation of harmonised methods for the measurement of the global profits of TNCs. Therefore, the efforts of the International Accounting Standards Committee (IASC) to produce international accounting standards and harmonised consolidation rules must be recognised and, if needs be, refined and ultimately implemented. * Third, the major function of Intertax would be to determine the commercial profits of TNCs on a standardised basis and to apportion the latter to relevant countries by way of an appropriate formula/formulas. Once this is achieved, each country would be free, starting from its share of commercial profits, to determine the taxable income in accordance with the particular tax base that it adopts and, ultimately, the tax payable within its jurisdiction. In the proposed system, therefore, a particular country would be able to independently set whatever depreciation schedules or investment tax credits it chooses, and adopt whatever tax accounting rules it deems fit relative to its policy objectives. Moreover, this thesis argues that the global formulary apportionment model it proposes is not dramatically opposed to the arm's length principle. Indeed, it suggests that the constant assumption to the contrary, even with regard to the usual formulary apportionment methodology, is extravagant because both methodologies are based on a common endeavour, that is, to give a substantially correct reflex of a TNC's true profits. It has often been objected that global formulary apportionment is arbitrary and ignores market conditions. This thesis addresses such concerns by rejecting the application of a single all-purpose formula. Rather, it recognises that TNCs operating in different industries require different treatment and, therefore, suggests the adoption of different formulas to satisfy specific industry requirements. For example, the formula applicable to a financial institution would be different to that applicable to the pharmaceutical industry. Each formula needs to be based on the fundamental necessity to capture the functions, taking into consideration assets used, and risks assumed within that industry. In addition, if the need arises, each formula should be able to be fine-tuned to fit specific situations. Moreover, it is also pertinent to note that the OECD already accepts 'the selected application of a formula developed by both tax administrations in cooperation with a specific taxpayer or MNE group...such as it might be used in a mutual agreement procedure, advance transfer pricing agreement, or other bilateral or multilateral determination.'6 The system proposed in this thesis can thus be easily reconciled with the separate accounting/arm's length which the OECD so vehemently advocates. Both models have the same preoccupations so that what is herein proposed may simply be characterised as an institutionalised version of the system advocated by the OECD. Multilateral formulary apportionment addresses both the double taxation and the allocation problems in international taxation. It resolves the apportionment question 'without depending on an extraordinary degree of goodwill or compliance from taxpayers.'7 It is therefore submitted that, if applied on a multilateral basis with a minimum of central coordination, it also seriously addresses the double taxation problem. Indeed, it is a flexible method given that different formulas may be devised to suit the needs of TNCs operating in different sectors. Consequently, formulary apportionment understood in this sense, is a realistic alternative to the limitations of the present system.

Thesis (Ph. D.)--University of Sydney, 2002.
Title from title screen (viewed Apr. 23, 2008). Submitted in fulfilment of the requirements for the degree of Doctor of Philosophy to the Faculty of Law. Degree awarded 2002; thesis submitted 2000. Includes bibliography. Also available in print form.

The European Commission is currently working on a legislative draft to harmonise the corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a Common Consolidated Corporate Tax Base (CCCTB) applicable for multinational companies. As the EU member states are not willing to surrender their taxing power to the supranational level of the EU each group entity's tax base would be determined by apportionment of the group's overall taxable income according to a predefined micro-economic factor based formula whereas the group income will be calculated by consolidating earnings beforehand separately determined by each group entity (preconsolidation income). The situs state of the particular group entity would then apply its statutory corporate tax rate on the apportioned tax base. This paper evaluates the effects of this prospective apportionment procedure on any given corporate group entity and finds that the share of the group's income allocated to a particular entity using the apportionment formula does regularly not equal the pre-consolidation income of the respective group entity. The reasons for this regular observable deviation can be found on the one hand in the concept of the apportionment formula and on the other hand in the specifics of the definitions of the apportionment factors. (author's abstract)
Series: Discussion Papers SFB International Tax Coordination

The European Commission on 16 March 2011 proposed a harmonized system for the tax base calculation of companies operating in the EU. The proposed Common Consolidated Corporate Tax Base (CCCTB) indicates that businesses would benefit from a "one-stop-shop" system for filing their tax returns and would be able to consolidate all the profits and losses they incur across the EU. Member States would maintain their full sovereign right to set their own corporate tax rate. However, many Member States are against this new system as they think that CCCTB does not meet principles of subsidiarity and proportionality and is not available to reach its goals. Therefore, the hypothesis of this Master Thesis was formulated that CCCTB is an appropriate way to reach company tax harmonization in the EU and abolish obstacles which arise because of 27 different taxation systems in EU. After comprehensive analysis of major company taxation obstacles in the first chapter, these main barriers were identified: double taxation, additional compliance cost, over-taxation which arise in cross-border activities. The main measures such as Parent-Subsidiary Directive, Merger Directive, Interest and Royalties Directive and Arbitration Convention designed to cope with these barriers were discussed and the main challenges needed to solve by CCCTB were formulated. Proposed Directive and main elements of CCCTB were investigated in the second chapter. As there is a disagreement between Member States regarding to... [to full text]
Europos Komisija 2011 m. kovo 16 d. pateikė pasiūlymą harmonizuoti pelno mokesčio bazės apskaičiavimą. Pasiūlyta Bendra konsoliduota pelno mokesčio bazė (BKPMB) reiškia, kad būtų taikomas „vieno langelio” principas pildant vieną deklaraciją ir įmonės galėtų konsoliduoti visą pelną ir nuostolius pagal bendras taisykles. Valstybės išlaikytų nepriklausomą teisę nustatyti apmokestinimo tarifus. Tačiau dauguma ES valstybių yra prieš šios sistemos įvedimą, jos savo prieštaravimus grindžia tuo, kad BKPMB pažeidžia subsidiarumo ir proporcingumo principus bei nėra pajėgi pasiekti savo tikslų. Dėl to buvo šiame darbe buvo iškelta hipotezė: BKPMB yra tinkamas būdas siekti įmonių apmokestinimo harmonizavimo ir panaikinti kliūtis, kurios kyla taikant 27 skirtingas apmokestinimo sistemas ES. Atlikus išsamią analizę pirmojoje dalyje šios pagrindinės kliūtys buvo nustatytos: dvigubas apmokestinimas, didelės mokestinių reikalavimų laikymosi sąnaudos bei tarpvalstybinės nuostolių užskaitos apribojimas. Taip pat buvo nagrinėjami pagrindiniai dokumentai: Direktyva dėl bendrosios mokesčių sistemos, taikomos įvairių valstybių narių patronuojančioms ir dukterinėms bendrovėms; Direktyva dėl bendros mokesčių sistemos, taikomos įvairių valstybių narių įmonių jungimui, skaidymui, turto perleidimui ir keitimuisi akcijomis; Direktyva dėl bendros apmokestinimo sistemos, taikomos palūkanų ir autorinių atlyginimų mokėjimams tarp skirtingų valstybių narių asocijuotų bendrovių; Konvencija dėl dvigubo... [toliau žr. visą tekstą]

The draft for a Common Consolidated Corporate Tax Base Directive in the European Union includes the suggestion for an apportionment formula which allocates taxable group profits to group member corporations. These allocated profits shall then be taxed in the respective Member States. The draft directive delegates the right to define one factor of the apportionment formula, the term "Employee" to the Member States, who are therefore free to choose a narrow or a broad definition, the latter including also atypical employment schemes. Using a game-theoretic approach the paper shows that the individually rational strategy of any Member State to define "Employee" broadly so as to maximize the volume of the apportionment factor and thus maximize the allocated share of taxable income is only the best solution when tax rate differences and differences in the volume of atypical employment schemes are disregarded. If such differentials and the corporate groups' reactions to different Member States' definitions are included in modelling the game's pay-offs a narrow definition of "Employee" yields the highest individual pay-offs to the Member States involved. This change of dominant strategies is triggered by the corporate group's shifting of the employment factor from high-tax to low-tax Member States. Our paper differs from previous research on the economic effects of the CCCTB apportionment formula as it is the first paper identifying and analysing the employment factor and its distorting effects. The paper discusses possible tax minimizing strategies for corporate groups by shifting workforce and develops a model to quantify these potential relocations. Furthermore the paper presents advice to policy makers in their "Employee" definition decision and shows how Member States could use this definition to both minimize outward factor shifting and maximize inward factor shifting.(authors' abstract)
Series: WU International Taxation Research Paper Series

Efter ett 10 årigt arbete mot att harmonisera direkt beskattning inom EU har Kommissionen lagt fram ett förslag till direktiv avseende en gemensam konsoliderad bolagsskattebas (CCCTB). Syftet med förslaget är att företag som bedriver gränsöverskridande verksamhet endast ska behöva följa en regeluppsättning samt arbeta gentemot en skattemyndighet. Tanken är att resultaten från alla koncernens bolag inom EU slås samman och sedan portioneras ut till koncernföretagen genom en fördelningsnyckel. Kommissionen har angivit att konsolideringen ska medföra att medlemsstaterna kan konkurrera på lika villkor och att fördelningen av skattebasen ska ske rättvist mellan medlemsstaterna. Det finns medlemsstater som är osäkra på förslagets konsekvenser och medlemsstaternas konkurrensmöjligheter efter förslagets antagande. Därav, är syftet med uppsatsen att utreda om fördelningsnyckeln i förslaget medför att skattebasen fördelas rättvist mellan medlemsstaterna genom att medlemsstaterna har möjlighet att konkurrera på lika villkor på den inre marknaden. Fördelningsnyckeln består av tre komponenter; arbetskraft, tillgångar och försäljning. Den gemensamma skattebasen portioneras ut till företagen i relation till företagets andel av koncernens totala andel av komponenterna. Därefter har medlemsstaterna rätt att beskatta andelen tillhörande företagen etablerade i medlemsstaten med den nationella skattesatsen. Uppsatsen innehåller en analys avseende de beståndsdelarna i fördelningsnyckelns komponenter som kan tänkas påverka medlemsstaternas möjlighet att konkurrera på lika villkor. Uppsatsen diskuterar hur beståndsdelarna påvekar konkurrensen samt i vissa fall ges förslag på förändringar som kan leda till att komponenten medför att medlemsstaterna kan konkurrera på lika villkor och därmed erhålla en rättvis fördelning av skattebasen.
After 10 years of work towards harmonization of direct taxation within EU the Commission has proposed a directive on a common consolidated corporate tax base (CCCTB). The aim of the proposal is that companies who engage in cross-border activities only need to comply with one set of rules and work towards one tax authority. The idea is that the result from all companies inside EU within the group should be pooled and then portioned out to the individual companies through an allocation formula. The Commission has stated that the consolidation shall result in that member states can compete on equal terms and that the tax base is apportioned fairly between the member states. However, there are member states that are doubtful of the consequences of the proposal and the member states competitive opportunities after the adoption. Therefore, the aim of this paper is to examine if the allocation formula in the proposal result in that the tax base are apportioned fairly between the member states through the member states possibility to compete on equal terms within the internal market. The formula for apportionment consist of three components; labor, assets and sales. The common tax base will be portioned out to the companies in relation to the share of the company compared to the total share of the group of each component. Then, the member states have the right to tax the share that belongs to the companies that are established within the member state with the national tax rate. The thesis contains an analysis of the elements in the components of the allocation formula that could affect the opportunity of the member states to compete on equal terms. The thesis discusses how the elements affect the competition and in certain cases suggestions of changes in the elements are given that could lead to that the component result in that the member states can compete on equal terms and thereby hold a fair share of the tax base.

碩士
國立高雄應用科技大學
財富與稅務管理研究所碩士在職專班
101
Cheap talk means preplay communication in game, costless, nonbinding, and not affects the payoff of the players. When the senders own the more information, can directly or through the mediators, transmit the message to the receivers and policymakers. This thesis introduces the cheap talk model. We analyze the formulation of the specifically selected goods and services tax act and securities transaction income tax. The government seeks social equity and justice using these taxation policies. The luxury tax and securities transaction income tax have many problems in existence, repeal and revision. They are not in equilibrium.

Currently the gold mining industry is taxed differently to other industries. It is taxed on a two-tier system. The nature of the gold mining tax formula encourages the mining of marginal gold ores. Firms that are involved in the mining of gold are subjected to a "tax tunnel", which is a tax free revenue portion. This is against the equity principle of taxation because it separates companies on the basis of what they produce and not on the basis of income generated. The South African government is in the process of implementing a revenue-based royalty system. The majority of firms in the gold mining industry feel that for the benefit of economic growth the government must consider implementing a profit-based royalty system. This study analyses the gold mining tax formula in comparison to the flat rate tax. It also analyses the reasons for the differential treatment of the gold mining industry.
Economics
M.Comm.

Small and medium enterprises (SMEs) play a significant role in the economy. However, SMEs face a number of obstacles and impediments that prevent them from developing and growing. Government has introduced a number of initiatives to help develop and promote SMEs but SMEs still face many remaining obstacles and impediments which include non-compliance with tax legislation. The main purpose of this dissertation is thus to help SMEs increase their level of tax compliance by developing a checklist of indicators that will help SMEs reduce the probability of tax errors occurring in respect of the gross income definition and general deduction formula. Other sections of the income tax and other tax types were not considered as the study was confined to the gross income definition and general deduction formula. These untouched areas may be considered in future research
Taxation
M. Compt.

The last chapter of the book reviews whether the international tax regime has been a success or a failure and based on these remarks, it is assessed what the reasons are for potential success and potential failure. Afterwards, reference is made to three of the most pressing issues in the current international tax regime. This includes measures against aggressive tax planning, specific issues triggered by the taxation of the digital economy, and a discussion of whether it would better to switch from the arm’s length principle to a formulary system. The chapter will also cover some of the most recent proposals to change the current international tax regime as part of the Pillar 1 and Pillar 2 work of the Inclusive Framework.

The asymmetry of the UK as a union means that England, unlike Scotland, Wales and Northern Ireland, not only has no domestic legislature but no executive of its own either. Westminster is England’s Parliament and the UK Government is England’s Government. Much attention has been devoted to the (parliamentary) anomaly of the West Lothian Question, but there has been little discussion of England’s Government. This chapter asks whether the UK Government contains a ghost in the machine: an embryonic English Government, perhaps in English departments or cabinet committees, or shown in social or economic policy or in taxation and spending. It notes how deeply entangled UK and English economic and fiscal policy are, notably via the Barnett formula, and considers the options for more explicit English governance such as a ‘Minister for England’, but questions how politically salient this would be when the main issue is England’s relations with Europe.

In Boolean games, each agent controls a set of Boolean variables and has a goal represented by a propositional formula. We study inference problems in Boolean games assuming the presence of a PRINCIPAL who has the ability to control the agents and impose taxation schemes. Previous work used taxation schemes to guide a game towards certain equilibria. We present algorithms that show how taxation schemes can also be used to infer agents' goals. We present experimental results to demonstrate the efficacy our algorithms. We also consider goal inference when only limited information is available in response to a query.

The existence of (Nash) equilibria with undesirable properties is a well-known problem in game theory, which has motivated much research directed at the possibility of mechanisms for modifying games in order to eliminate undesirable equilibria, or induce desirable ones. Taxation schemes are a well-known mechanism for modifying games in this way. In the multi-agent systems community, taxation mechanisms for incentive engineering have been studied in the context of Boolean games with costs. These are games in which each player assigns truth-values to a set of propositional variables she uniquely controls in pursuit of satisfying an individual propositional goal formula; different choices for the player are also associated with different costs. In such a game, each player prefers primarily to see the satisfaction of their goal, and secondarily, to minimise the cost of their choice, thereby giving rise to lexicographic preferences over goal-satisfaction and costs. Within this setting, where taxes operate on costs only, however, it may well happen that the elimination or introduction of equilibria can only be achieved at the cost of simultaneously introducing less desirable equilibria or eliminating more attractive ones. Although this framework has been studied extensively, the problem of precisely characterising the equilibria that may be induced or eliminated has remained open. In this paper we close this problem, giving a complete characterisation of those mechanisms that can induce a set of outcomes of the game to be exactly the set of Nash Equilibrium outcomes.