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1
Piketty, Thomas, Gilles Postel-Vinay, and Jean-Laurent Rosenthal. "Wealth Concentration in a Developing Economy: Paris and France, 1807–1994." American Economic Review 96, no. 1 (2006): 236–56. http://dx.doi.org/10.1257/000282806776157614.
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Using large samples of estate tax returns, we construct new series on wealth concentration in Paris and France from 1807 to 1994. Inequality increased until 1914 because industrial and financial estates grew dramatically. Then, adverse shocks, rather than a Kuznets-type process, led to a massive decline in inequality. The very high wealth concentration prior to 1914 benefited retired individuals living off capital income (rentiers) rather than entrepreneurs. The very rich were in their seventies and eighties, whereas they had been in their fifties a half century earlier and would be so again after World War II. Our results shed new light on ongoing debates about wealth inequality and growth.
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Yarovа, Nina, Olha Vorkunova, and Vira Baryshnikova. "FOREIGN EXPERIENCE OF STATE SUPPORT OF INNOVATIVE ACTIVITIES (MACRO- AND MICROECONOMIC ASPECTS)." Development of Management and Entrepreneurship Methods on Transport (ONMU) 83, no. 2 (2023): 5–18. http://dx.doi.org/10.31375/2226-1915-2023-2-05-18.
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The foreign experience of state support for innovative activities of enterprises at both the macro and micro levels is discussed in the article.An important condition for the dynamic development of the country at the macro level is the accelerated introduction of modern innovative technologies in the economic, social and other spheres with the wide use of the achievements of science and technology.All rapidly developing spheres of public and state life of the country require close support of the reforms on the basis of modern innovative ideas, developments and technologies that ensure a quick and high-quality breakthrough of the country in this area of activity.State regulation of the economy and innovation processes on the macro level,according to scientists, is one of the main conditions for transferring the functioning of the economy to market relations. The main function of the state in the conditions of market relations is the protection of individual freedom, property and entrepreneurship. The government is obliged to work with the market in one harness.To overcome the crisis on the macro level, it is necessary to develop a strategy for maintaining and developing the scientific, technical and innovative potential of the country in the following areas: restructuring the scientific and technical potential in various sectors of the economy, taking into account the concentration of material, financial and intellectual resources; creation of a science and innovation property fund; development of a system for the use of leasing as an effective market mechanism for subjects of innovative activity; improving the mechanisms of the system for attracting bank loans to expand innovation and create conditions for the development of the capital market; creation in financial and industrial groups along with the system of consolidation of financial and production potentials of special innovation centers coordinating and implementing innovative projects; formation of an institute of developers of innovative projects from among scientific and technical workers, scientists and specialists; formation on the basis of funds supporting innovative activity, associations of funds with developed financial capital to help innovative projects; formation of a system for the targeted use of depreciation fund funds to finance activities related to R&D, experimental and other types of work, development of innovations, patenting of new solutions; improvements in tax legislation, which will increase innovation activity.In recent years, in the economically developed countries of the world, there has been a trend towards the widespread use of indirect stimulation methods on a par with direct ones. This is due to the fact that tax benefits involve much less intervention by the state in the economic life of an enterprise and they encourage already embodied actions, while subsidies only those that have yet to be implemented.An important role on the macro and micro level is played by tax incentives, which are used to develop the activities of enterprises that are aimed at stimulating scientific and technological progress and innovation.Some foreign countries use both types of tax discounts at the same time – both volumetric and incremental, but in relation to different types of expenses:in the USA, for private sector expenditures on fundamental research funding, the general incremental discount was supplemented by a volume discount of 20%;in France, newly established small and medium-sized companies are temporarily exempted from paying income tax or have a «tax holiday» with a reduction of 50% of the income tax they pay for the first five years of their activity;in Great Britain, the tax for innovative startups has been reduced from 20%to 1%.The experience of the USA, where the state encourages the interaction of enterprises and higher education institutions in the field of scientific and research work by providing tax benefits, should be used in Ukraine.Businesses provide necessary equipment to universities free of charge and are able to deduct the cost of this equipment from their gross income. This will make it possible to create powerful research centers on the basis of higher educational institutions of the country.In France, the state encourages personnel training:25% of the increase in personnel training costs are exempt from taxes;personnel training costs are not taxed at all if there is high unemployment.One of the methods that has the greatest value as a benefit is the accelerated depreciation method:in Germany, accelerated depreciation is applied in agriculture (up to 50% of the cost of equipment is written off in the first year, up to 80% in the first three years).Among the indirect economic measures of state regulation of innovative activity in the EU countries is the policy of industrial protectionism for the protection and implementation of innovations in the country.Keywords: state support, micro-macroeconomic aspect, innovation activity, strategy, world economy.
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Smith, Julie P. "Progressivity of the Commonwealth Personal Income Tax, 1917-1997." Australian Economic Review 34, no. 3 (2001): 263–78. http://dx.doi.org/10.1111/1467-8462.00195.
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Morozova, O. M., and T. I. Troshina. "The Russian Income Tax Against the Background of the Sociopolitical Events of 1917–1920s." Modern History of Russia 13, no. 2 (2023): 322–38. http://dx.doi.org/10.21638/spbu24.2023.204.
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The introduction of income tax in Russia has a long history, but not all stages of this process have been covered in scholarly publications. Due to the low efficiency of the tax institutions of the post-revolutionary governments, their law-making activities and attempts to collect income tax in 1917–1921 remain under-researched. What little the Soviet and White governments had in common was their willingness to base their fiscal practices on the imperial legislation. The practice of application revealed differences. The Bolsheviks consistently developed the existing framework, trying to find forms of tax collection appropriate to the country’s situation despite a long phase of failure in their attempts. Not only the central authorities, but also the county councils and congresses were given greater freedom in rulemaking. In contrast to this experience, the opponents of the Soviet power, didn’t work out the contours of the emergency financial system. The decrees and orders of the White governments were only created to respond to inflationary processes. The construction of the peacetime tax system continued under the extraordinary conditions of economic crisis and famine. The Soviet government and the People’s Commissariat of Finance did not abandon the idea of the income tax, considering its presence a sign of maturity of the tax system and the guarantee of stability of revenue receipts in the budget. At the stage of the class struggle in the economic sphere in the 1920s, it was used as a tool to restrain the growth of bourgeois elements in trade and production. The introduction of this type of tax in the agricultural collective sector lasted for decades. Sporadic attempts to use it in the 1920s were unsuccessful. It was not until 1992 that it took the form of a personal income tax.
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Cremer, Helmuth, Firouz Gahvari, and Norbert Ladoux. "Income Tax Reform in France: A Case Study." FinanzArchiv 66, no. 2 (2010): 121. http://dx.doi.org/10.1628/001522110x524179.
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Voroshilo, Viktoria Viktorovna. "EXPERIENCE WITH TAX CRIMES IN FRANCE." Scientific Bulletin: finance, banking, investment., no. 2 (55) (2022): 31–39. http://dx.doi.org/10.37279/2312-5330-2021-2-31-39.
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The article considers the tax legislation of France aimed at combating tax crimes. The author’s research conducted in relation to tax violations in France shows interest in the selected study. The fight against tax crimes is of great importance for the economy of any state, including the positive experience of foreign countries. An algorithm of interaction between tax authorities and tax payers in the detection of tax offenses has been developed. The types of tax violations in France and the consequences of their detection for taxpayers are considered. The influence of the adopted tax legislation on the collection of taxes is studied. Namely, an increase in the recovered amounts to the state’s budget based on the results of tax investigations. The analysis of statistical data of tax offenses, tax investigations, which allowed to argue the consequences of the introduced norms, was carried out. The structure of tax crimes by the nature of their implementation over 5 years in France is considered and it is revealed that in recent years crimes of hiding income and undeclared income prevail. The structure of tax crimes, which were carried out in different spheres of the economy, where the most prone to crime is the service sector, is studied. Over a two-year period, the fines received based on the results of the sentences imposed in quantitative and qualitative composition were studied. The interrelation of the recovery of funds from the fight against tax crimes in favor of the state for the period 2010-2018 is studied. The main instruments were one-time fines and recoveries of amounts in accordance with the adopted tax legislation.
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Magnani, Riccardo, and Luca Piccoli. "Universal basic income with flat tax reform in France." Journal of Policy Modeling 42, no. 2 (2020): 235–49. http://dx.doi.org/10.1016/j.jpolmod.2019.07.005.
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Muehlbacher, Stephan, Erich Kirchler, Erik Hoelzl, et al. "Hard-Earned Income and Tax Compliance." European Psychologist 13, no. 4 (2008): 298–304. http://dx.doi.org/10.1027/1016-9040.13.4.298.
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Is the effort invested to achieve taxable income a relevant factor for tax compliance? If the value of income increases with the effort exerted, reluctance to pay taxes should be high. On the other hand, if income is perceived as compensation for one’s endeavor, there is too much at stake to take the risk of being audited and paying a fine. Consequently, tax evasion should be more likely if income was obtained easily. These contradicting predictions were tested in a questionnaire study with samples from eight countries (Australia, Austria, England, France, Italy, New Zealand, Spain and Switzerland; N = 1,223). Results show that the effort exerted to obtain taxable income and the aspiration level matter in compliance decisions. Hard-earned money is more likely to be reported honestly to tax authorities, particularly if the aspiration level can be satisfied by honest tax reporting.
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Dulamsuren, Nyamaa, and Khatantumur Minjin. "A Study on the Improvement of Income Tax reporting For Business Combinations in Mongolia." International Journal of Economics, Business and Management Research 08, no. 06 (2024): 87–102. http://dx.doi.org/10.51505/ijebmr.2024.8607.
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In line with the international trend and practice of deeming associated entities as a single economic unit and assessing the taxable income at the group level based on the consolidated income tax statements, many countries in the world including the United States, Australia, New Zealand, and France allow the preparation of consolidated income tax returns and provide special tax credits and exemptions for transactions between the parent and subsidiaries companies of the group, unrealized gains (losses) arising from them, and intercompany dividends. This study aims to examine the needs and demand to prepare a consolidated income tax report, the current practice of business combinations to file income tax returns, and some issues related to the methodology of preparing a consolidated income tax statement. This study also attempts to prepare a consolidated income tax statement form for national business combinations according to the international trend within the framework of the currently acting laws and regulations of Mongolia and to prepare recommendations for improving the consolidated income tax reporting for the business combinations. This paper uses a Ten-step methodology for recording the impact of income tax within the framework of IFRS used in the research of B.Byambakhishig (2017). Our data covers separate financial statements, income tax reports, intercompany transactions, and other related financial data of "AM" LLC (Canadian-invested mining company) and its fully controlled "ASI" LLC, which operates business in mining subcontracting, software development, and analytics. The study lacks a recording of the impact of income tax and income tax consolidation, therefore, a further study will be conducted on the consideration related to the analysis of the Consolidated Income Tax Statements.
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Piketty, Thomas, and Emmanuel Saez. "How Progressive is the U.S. Federal Tax System? A Historical and International Perspective." Journal of Economic Perspectives 21, no. 1 (2007): 3–24. http://dx.doi.org/10.1257/jep.21.1.3.
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This paper provides estimates of federal tax rates by income groups in the United States since 1960, with special emphasis on very top income groups. We include individual and corporate income taxes, payroll taxes, and estate and gift taxes. The progressivity of the U.S. federal tax system at the top of the income distribution has declined dramatically since the 1960s. This dramatic drop in progressivity is due primarily to a drop in corporate taxes and in estate and gift taxes combined with a sharp change in the composition of top incomes away from capital income and toward labor income. The sharp drop in statutory top marginal individual income tax rates has contributed only moderately to the decline in tax progressivity. International comparisons confirm that is it critical to take into account other taxes than the individual income tax to properly assess the extent of overall tax progressivity, both for time trends and for cross-country comparisons. The pattern for the United Kingdom is similar to the U.S. pattern. France had less progressive taxes than the United States or the United Kingdom in 1970 but has experienced an increase in tax progressivity and has now a more progressive tax system than the United States or the United Kingdom.
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Tillotson, Shirley. "A History of Canadian Income Tax. Volume 1: The Income War Tax Act 1917–1948. Colin Campbell and Robert Raizenne." Canadian Historical Review 105, no. 1 (2024): 154–56. http://dx.doi.org/10.3138/chr.105.1.rev7.
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Rhein, Jonathan. "Selected US Tax Developments: Canadian Residents Who Are US Citizens May Be Able To Credit Canadian Taxes Against the US Net Investment Income Tax." Canadian Tax Journal/Revue fiscale canadienne 71, no. 4 (2022): 1171–76. http://dx.doi.org/10.32721/ctj.2023.71.4.ustd.
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The US net investment income tax (NIIT, colloquially referred to as the "Obamacare tax" or "Medicare tax") is a 3.8 percent tax on worldwide investment income of US citizens and residents, and applies to interest, dividends, royalties, and other types of investment income. Although US domestic law does not permit a foreign tax credit to be applied against the NIIT, the US Court of Federal Claims recently held that the US-France tax treaty requires the United States to allow a foreign tax credit against the NIIT. While this case may be helpful for US citizens who are residents of other countries that have tax treaties with the United States that include provisions similar to the provision at issue in the case, residents of Canada who are US citizens may have a harder time making the argument that the US-Canada tax treaty requires the United States to allow a foreign tax credit against the NIIT.
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Teremetskyi, Vladislav I., Oleksandr M. Bandurka, Emiliia S. Dmytrenko, Nataliа I. Atamanchuk, and Oleksandra O. Kochura. "Assessed taxation in the health care sector in Ukraine and foreign countries: comparative and legal analysis." Wiadomości Lekarskie 73, no. 2 (2020): 374–79. http://dx.doi.org/10.36740/wlek202002132.
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The authors have defined and revealed the mechanism for collecting personal income tax, value added tax, single tax relating to health care sector in Ukraine and their analogues in other countries. Special attention has been paid to the problems in this field in Ukraine and the ways of their solution have been suggested. It has been proved that the mechanism of legal regulation of assessed taxation in the health care sector in Ukraine needs to be improved. Taking into account international experience, the authors have offered to amend the Tax Code of Ukraine on: the use of tax incentives of state support (USA); progressive assessed taxation of individual income (Spain, Germany, Poland, Slovakia, etc.); value added tax rates and benefits (USA, France, Hungary) and so on.
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Burzec, Marcin, and Michalina Duda-Hyz. "THE TAXATION OF THE SO-CALLED DIRECT SALES IN THE POLISH PERSONAL INCOME TAX IN COMPARATIVE PERSPECTIVE." Review of European and Comparative Law 2627, no. 34 (2016): 9–25. http://dx.doi.org/10.31743/recl.4975.
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Article presents the principles for the taxation of the so-called direct sales of agricultural products on the basis of the personal income tax. The first part of the article includes remarks concerning the regulations introduced into the Polish legal system by way of the revision of the Pesonal Income Tax Law of April 2015. The second part of the article presents the principles of the so-called direct sales in France and Italy.
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Duquette, Nicolas J. "Founders’ Fortunes and Philanthropy: A History of the U.S. Charitable-Contribution Deduction." Business History Review 93, no. 3 (2019): 553–84. http://dx.doi.org/10.1017/s0007680519000710.
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Since 1917, tax filers in the United States who itemize tax deductions have been able to subtract gifts to eligible charities from their taxable income. The deduction is especially valuable to successful entrepreneurs who donate corporate stock. Such philanthropy was seen as a close substitute for government spending until after the mid-twentieth century. In the 1950s and 1960s, high tax rates catalyzed the formation of large foundations from industrial fortunes and precipitated a national debate about the legitimacy of such giving. The midcentury debate preceded increased oversight of charities and foundations and a shift in the way U.S. lawmakers regarded the contribution deduction—from a subsidy by philanthropists of public goods government would otherwise provide to an implicit public cost.
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Fack, Gabrielle, and Camille Landais. "Are Tax Incentives for Charitable Giving Efficient? Evidence from France." American Economic Journal: Economic Policy 2, no. 2 (2010): 117–41. http://dx.doi.org/10.1257/pol.2.2.117.
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This paper estimates the effect of tax incentives for charitable contributions in France. We focus on two reforms that increased the nonrefundable tax credit rate for charitable contributions by 32 percent. We use a difference-in-difference identification, comparing the evolution of contributions for groups of households with similar income, but different taxable status due to differences in family size. We control for censoring issues and investigate distributional effects using a three-step censored quantile regression estimator. We find that the price elasticity of contributions is relatively small, but tends to increase with the level of gifts. (JEL D14, D64, H24)
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Alla, Mikel. "Characteristics of the VAT in Albania." European Journal of Social Sciences Education and Research 1, no. 1 (2014): 228. http://dx.doi.org/10.26417/ejser.v1i1.p228-233.
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The value added tax (taxe sur la valeur ajoutee - TVA) was "invented" by a finance expert of France called "Maurice Laure" (1917-20 April 2001). The system of "Laure" is designed to April 10, 1954. He "invented" a tax on consumption, which was called the VAT (TVA). His idea was quickly adopted because it compels taxpayers at all levels of the production process, for self-management and self-calculating the tax, instead of putting the burden on sellers, or the tax authorities make the tax assessments. The tax legislation for the VAT in Albania has changed constantly . The VAT in Albania is regulated by the Law No. 7928 dated 27.04.1995 "On the VAT" . This law was amended to date from about 30 other laws . in the design of the fiscal policy of Albania , are taken into consideration the behavior of taxpayers and their ability to the tax evasion . Albanian state is trying to harmonize the fiscal legislation with those of the other countries of the European Union. This paper aims to show the main characteristics of the VAT in Albania . At the end of this paper, I will give my conclusions of the issue .
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ANUREEV, Sergei V. "Adjustments of VAT and income tax of banks." Finance and Credit 30, no. 4 (2024): 726–47. http://dx.doi.org/10.24891/fc.30.4.726.
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Subject. The article discusses excess profits of Russian banks in the amount of the planned Federal budget deficit in 2023, and financial relationships between banks and the budget as causes of excess profits. Objectives. The focus is on fairer taxation of commercial banks, using the case of the largest of them, and based on the latest experience of other countries. Methods. The study employs the comparative analysis of other countries’ practice on modifying the taxation of super profits of banks, financial analysis of reports of the largest banks regarding the specifics of the main taxes. Results. The article shows a zero net impact on the budget from bank operations. Budget payments by banks include income tax, tax on dividends, dividends to the State owned shares. Indirectly banks pay VAT on interest on corporate loans, interest on treasury funds in banks. Payments from the budget to banks include OFZ coupons and interest rate subsidies, banks earn margin on the treasury funds, zero VAT tax expenses on bank transactions with individuals. The international experience shows that other countries actively modify taxes on banks’ super profits. Italy and Spain introduced special taxes on banks, Brazil – a tax on financial transactions, Germany and Britain raised income tax rates, the U.S. regularly collect multi-billion dollar fines, France levies VAT on banks and encourages the European Union to do so. Conclusion. The fiscal effect of my proposals is about 1 trillion rubles, or one-third of the budget deficit. I offer to abolish zero VAT on bank operations with individuals, based on excess profits of banks, social inequality, and digitalization of tax control. Income tax for banks should be a minimum of 1% of risky assets, and it can be used to directly subsidize interest rates at the level of specific banks.
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Courtioux, Pierre, and Lucie Gadenne. "Inégalités et prélèvements obligatoires en France : l’apport d’une méthode de microsimulation avec bootstrap." Économie appliquée 63, no. 2 (2010): 5–22. http://dx.doi.org/10.3406/ecoap.2010.1942.
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This article offers a new approach of the micro simulation analysis of fiscal systems thanks to a model including four major French taxes and the bootstrap technique. We compare the redistributive impact of an increase in fiscal revenue for different fiscal instruments and confirm the well-known result of the strongly redistributive impact of the income tax and the regressive one of the VAT. Our methodological contribution consists in the construction of confidence intervals for the semi-elasticities of Gini coefficients to the use of each tax.
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Egorova, Maria A., Vladislav V. Grib, Liudmila G. Efimova, Olga V. Kozhevina, and Vitalii Yu Slepak. "Research of the effectiveness of the system of legal regulation of tax relations for operations with cryptocurrency currently in force." Vestnik of Saint Petersburg University. Law 14, no. 3 (2023): 564–79. http://dx.doi.org/10.21638/spbu14.2023.301.
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The article deals with the national practicies of direct and indirect taxation of income from cryptoassets in some countries of the world, including Russia, France, Italy, USA, Great Britain, etc. The authors study various approaches to the concept of cryptocurrency for the purposes of fiscal management: macroeconomic, cost, accounting, legal and institutional approaches. According to the authors position cryptocurrencies for tax reasons should be treated as a property and means of payment. Therefore, any income in cryptocurrencies received by taxpayers should be subject to personal income tax or corporate income tax, respectively. The recognition of cryptocurrencies as a means of payment (that is, private money) leads to the need to exempt taxpayers from paying value added tax in cases where cryptocurrencies perform these monetary functions in transactions performed by taxpayers, in particular, they perform the function of a means of payment. Payment of taxes on income of taxpayers received in cryptocurrencies can be carried out both in cryptocurrencies and in national (fiat) currencies. It is permissible to establish a tax declaration of transactions for cryptocurrency. The foundations of the legal regime of taxation of digital currencies in the Russian Federation have been formed. The problems of introducing effective taxation of cryptocurrency transactions in the Russian Federation are identified, as well as changes to tax legislation are proposed, in particular, clarification of the range of objects that can be classified as “digital currency”, synchronization with the law on digital financial assets, determining the tax base and implementing tax control of transactions with cryptocurrency. As the study showed, the approaches to indirect taxation are the most unified. Tax regulation is a potential incentive to reduce the speculative interest of participants in transactions with cryptocurrencies and increase the transparency of taxation of cryptocurrencies.
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ARCHVADZE, JOSEPH. "TAX BURDEN OF EMPLOYED PERSONS." Globalization and Business 4, no. 7 (2019): 79–86. http://dx.doi.org/10.35945/gb.2019.07.010.
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Tax burden demonstrates very precisely the scope of fiscal pressure on business and population by the state. In Georgia physical persons are taxed as by direct taxes (income tax is 20%), as indirect taxes. In the end they have much influence on population’s purchasing power. More than population’s cash income comes from the salaries, accordingly income tax, VAT and excise could be considered as the tax burden of salaries. According to the calculation by this principle, the salary tax burden in Georgia is 39.2 %. In the last 7 years (In comparison with the year 2012) because of the rapid growth of indirect taxes, the mentioned burden has been increased by 2.7 point. To compare the salary tax burden with the European Union countries it is complicated, because since 2008 there is annulled social tax in Georgia, which is paid by employee and employer in Europe. There could be made the comparison if according to the European countries we compare the tax burden value with single workplace, which consists of social taxes paid by salary receivers and employers (contributions). Accordingly, what we will compare with Georgian index the share of direct and indirect taxes in whole salaries, or all tax shares in workplace value, Georgia with tax size will be on leader position (according to the first position) or in outsiders (according to the second position). That means, that in joint list of the EU and Georgia, with the sum of income tax and VAT in comparison with accrued salary, Georgia will be on the second place (39.2%; on the first place is Dania-40.7%) and by the real tax burden of workplace value - on 24th place (On the first place is France-56.7%, on the last place is Cypros-23.4%).
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ARCHVADZE, JOSEPH. "TAX BURDEN OF EMPLOYED PERSONS." Globalization and Business 4, no. 7 (2019): 79–86. http://dx.doi.org/10.35945/gb.2019.07.010.
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Tax burden demonstrates very precisely the scope of fiscal pressure on business and population by the state. In Georgia physical persons are taxed as by direct taxes (income tax is 20%), as indirect taxes. In the end they have much influence on population’s purchasing power. More than population’s cash income comes from the salaries, accordingly income tax, VAT and excise could be considered as the tax burden of salaries. According to the calculation by this principle, the salary tax burden in Georgia is 39.2 %. In the last 7 years (In comparison with the year 2012) because of the rapid growth of indirect taxes, the mentioned burden has been increased by 2.7 point. To compare the salary tax burden with the European Union countries it is complicated, because since 2008 there is annulled social tax in Georgia, which is paid by employee and employer in Europe. There could be made the comparison if according to the European countries we compare the tax burden value with single workplace, which consists of social taxes paid by salary receivers and employers (contributions). Accordingly, what we will compare with Georgian index the share of direct and indirect taxes in whole salaries, or all tax shares in workplace value, Georgia with tax size will be on leader position (according to the first position) or in outsiders (according to the second position). That means, that in joint list of the EU and Georgia, with the sum of income tax and VAT in comparison with accrued salary, Georgia will be on the second place (39.2%; on the first place is Dania-40.7%) and by the real tax burden of workplace value - on 24th place (On the first place is France-56.7%, on the last place is Cypros-23.4%).
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Lamensch, Marie. "Swiss Court Denies European Frontier Workers Their ‘Schumacker’ Rights (Comment on the 31 August 2009 Decision of the Geneva-Based ‘Commission Cantonale de Recours en Matièt." Intertax 38, Issue 2 (2010): 93–104. http://dx.doi.org/10.54648/taxi2010009.
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The Community law principle of free movement of persons entails a broad prohibition of discrimination including by means of tax provisions. The Bilateral EU-Swiss Treaty on free movement of persons contains this same prohibition of discrimination and refers for its proper interpretation to the case law of the European Court of Justice (ECJ). In the recent Boitelle case, however, a Swiss court did not apply the relevant ECJ case law (Schumacker) when upholding source-based taxation rules that discriminate against ‘frontaliers’ who work in Switzerland but live in France. This note first discusses the legal framework (Community law, the EU-Swiss treaty, income tax implications for ‘frontaliers’). It subsequently summarizes the Boitelle case (facts, arguments, decision of the court). Finally, it places the decision of the Swiss court in the context of settled ECJ internal market and income tax case law.
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Zielke, Rainer. "Transfer Pricing of Mayor EC Member Countries with Reference to the 2014 Corporate Income Tax Burden of the Thirty-Four OECD Member Countries Germany, France, United Kingdom, and Italy Compared." EC Tax Review 23, Issue 6 (2014): 332–51. http://dx.doi.org/10.54648/ecta2014032.
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In the February 2014 issue of the EC Tax Review, the author compared the anti-avoidance legislation in the mayor EC Member Countries Germany, France, United Kingdom and Italy and suggested some international tax planning strategies - without regard to transfer pricing (part 1). The author now considers transfer pricing involving these mayors EC Member Countries Germany, France, United Kingdom, and Italy and suggests further transfer pricing strategies also with regard to the up-to-date CIT rates in OECD countries (part 2). As stated, despite continuous instability in the European Community (EC) its mayor countries Germany, France, the United Kingdom, and Italy exhibit continuously economic growth and stability. According to the International Monetary Fund these European countries have - in this order - the highest gross domestic product in the European Community in 2012. In this article transfer pricing rules of - according to the gross domestic product - the four most important EC Member Countries will be reviewed with reference to the OECD's perspective of Base Erosion and Profit Shifting (BEPS) and to the up-to-date tax differential to the thirty-four OECD Member Countries. The pivotal question is, to what extent can internal tax planning with mayor EC Member Countries be optimized by inclusion of transfer pricing. This article outlines the primary corporate objective and key concepts of international tax planning with regard to transfer pricing and discusses the corporate income tax burden in the thirty-four OECD Member Countries analysing the tax differential as incentive in relation to transfer pricing, the reduction in ETR as the primary corporate objective and key concepts and the he importance of current and reliable information. After that transfer pricing in the mayor EC Member Countries Germany, France, United Kingdom, and Italy is presented and transfer pricing strategies with relation to mayor EC Member Countries are developed. Afterwards this is evaluated from the OECD's perspective of BEPS. Finally the concluding remarks are presented.
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DE MENIL, GEORGES, FABRICE MURTIN, and EYTAN SHESHINSKI. "Planning for the optimal mix of paygo tax and funded savings." Journal of Pension Economics and Finance 5, no. 1 (2006): 1–25. http://dx.doi.org/10.1017/s1474747205002283.
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We analyze the optimal balance between social security taxation and private saving in the provision of retirement income in dynamically efficient economies, a question at the center of policy debates in Europe and the United States. We consider the relative importance for this question of the return to capital, the internal return of the pay-as-you-go system, and the variabilities and correlation (or independence) of labor earnings and the capital return. We analyse these influences theoretically in the context of a two-period, overlapping generations model with uncertainty. We use a new method to calibrate the model using annual data on GDP per worker and the total real return on equities, from 1950 to 2002, from which we infer the stochastic characteristics of lifetime labor income and the return to lifetime savings in the US, UK, France and Japan. We obtain a range of optimal, steady-state values of the social security tax and the rate of lifetime savings. When the relative rate of risk aversion is assumed to be 2.5, the computed optimal tax varies from 5% in the United States to 22% in Japan. France is similar to Japan, and the UK is in between.
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Poras, Geoffrey, Agnès Charpenet, Michael Jaffe, and Elliott Murray. "Country note: Implementation of Current Withholding Tax in France: The French Exception is Gone!" Intertax 47, Issue 3 (2019): 298–303. http://dx.doi.org/10.54648/taxi2019027.
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Almost every developed country has put in place a system of current year withholding. What better way to ensure that taxes will be paid than to require the employer to withhold current year taxes from current year wages! Yet France has been virtually the last country to change from its current system where payment is made the year after income is earned and the employer is completely eliminated from the tax process. Each time moving from the old system to the standard current year withholding system has been discussed, resistance to change has prevailed. This time, after some last minute prevarication, President Macron will be leading the country forward with the reform starting 1 January 2019. It is important to understand what changes are in store, what happens during the 2018 transition tax year, and some unintended consequences on US taxpayers residing in France. We will first review how the new French withholding tax applies to salaries. We will then examine the transition measures that have been put in place to avoid tax abuse and yet avoid double taxation. Finally, we will look at an exceptional issue that the transition creates for US taxpayers residing in France for whom immediate action may be necessary.
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Cui, Wei. "The Digital Services Tax on the Verge of Implementation." Canadian Tax Journal/Revue fiscale canadienne 67, no. 4 (2019): 1135–52. http://dx.doi.org/10.32721/ctj.2019.67.4.sym.cui.
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France enacted the digital services tax (DST) in 2019, and similar legislation is pending in the United Kingdom, Spain, Italy, and other countries. The DST can be viewed as a tax on location-specific rent (LSR), and it arguably solves genuinely new problems in international taxation. The author briefly reviews this justification of the DST and further examines the DST design in light of three criticisms. The first criticism is that certain features of the DST render it similar to distortionary import tariffs. The second is that the DST would not be borne by digital platforms but would only be shifted to platform users. The third is that governments promoting the DST seem not to characterize it as a tax on LSR but, instead, have advocated reforming the income tax. The author suggests ways of rationalizing the DST's tariff-like features, refutes casual arguments about the DST's incidence, and offers a framework for understanding why small economies might advocate simultaneously for the DST and for the reformation of international income taxation.
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Vega, Alberto. "Andorra: Exchange of Information and New Tax System in the Context of the OECDs and EUs Initiatives." Intertax 43, Issue 2 (2015): 199–208. http://dx.doi.org/10.54648/taxi2015017.
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Andorra, a microstate located in the Pyrenees, between France and Spain, used to be characterized by strict bank secrecy and the absence of direct taxes on income. However, given the pressure exerted by the European Union and, especially, by the OECD, Andorra finally committed in 2009 to exchanging tax information upon request according to the OECD standards. Since then, Andorra has introduced important legal reforms following these standards, in a process which is still evolving and which may even lead to automatic exchange of information in the near future. Moreover, as a result of the crisis suffered in recent years, Andorra has also undergone a complete reform of its tax system and has approved, for the first time in the history of the country, a corporate and a personal income tax, even though the fiscal pressure is still very low. The aim of this article is to systematically analyse this major transformation of the Andorran legal framework in the context of the initiatives undertaken by the EU and the OECD in tax matters.
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MIN, You-ki. "Social Conflicts and Mitigation in France Regarding Wealth Tax and Minimum Income, 1981-2019." Korean Historical Review 249 (March 31, 2021): 43–75. http://dx.doi.org/10.16912/tkhr.2021.03.249.43.
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Bono, Pierre-Henri, and Alain Trannoy. "The Impact of the ‘Scellier’ Income Tax Relief on Building Land Prices in France." Economie et Statistique / Economics and Statistics, no. 507d (July 11, 2019): 91–114. http://dx.doi.org/10.24187/ecostat.2019.507d.1976.
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Mititelu, Roxana Adriana, Bogdan Florian Amzuică, Alina Chiriac, and Ileana Nișulescu. "Fiscal morality and the underground economy in countries of the European Union and the USA." Technium Social Sciences Journal 36 (October 8, 2022): 275–84. http://dx.doi.org/10.47577/tssj.v36i1.7473.
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The research was conducted to explore fiscal morality and underground economy of European countries and the US. The study was based on the assumption that the growth rate of an economy has a significant influence on tax compliance. In addition, the research investigated the effect of other factors on tax compliance of various countries. The factors included life expectancy, GDP growth rate, expenditure on education, and proportion of people living below the median income. Tax revenue was used to represent the level of tax compliance. The nations considered for this study included Germany, Italy, France, UK, and the US. Data was obtained from the World Bank Database, for the period 1971-2020. The findings depicted that economic growth was negatively associated with tax revenue. However, life expectancy, education expenditure, and poverty levels had a positive association with tax revenue. The regression models indicated that Italy had the most suitable model for estimation of tax compliance of fiscal morality among the selected countries.
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Billings, B. Anthony, and William H. Volz. "U.S. Tax Policy Towards Foreign Operations Hamper International Competitiveness Of U.S. Multinationals." Journal of Applied Business Research (JABR) 10, no. 2 (2011): 74. http://dx.doi.org/10.19030/jabr.v10i2.5940.
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<span>This article compares U.S. taxation of foreign source income along with domestic tax incentives with that of other major industrialized nations such as the U.K., Canada, Germany, France, and Japan. The paper point out that U.S. tax policy towards the profitability and expansion of foreign operations ignores the economic realities of the 1990s. In addition, revenue-raising concerns of the U.S. tax policy appear to override international competitiveness considerations. The article calls on U.S. tax policymakers to (1) find ways to establish U.S. business presence in the emerging markets of Europe and the Pacific Rim; (2) reverse the declining trend in the U.S. share of exports of technology intensive products; (3) find ways to meaningfully lower the cost of capital to U.S. businesses; and (4) find practical solutions for both the budget and trade deficit.</span>
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Bartels, Charlotte. "Top Incomes in Germany, 1871–2014." Journal of Economic History 79, no. 3 (2019): 669–707. http://dx.doi.org/10.1017/s0022050719000378.
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This study provides new evidence on top income shares in Germany from industrialization to the present. Income concentration was high in the nineteenth century, dropped sharply after WWI and during the hyperinflation years of the 1920s, then increased rapidly throughout the Nazi period beginning in the 1930s. Following the end of WWII, German top income shares returned to 1920s levels. The German pattern stands in contrast to developments in France, the United Kingdom, and the United States, where WWII brought a sizeable and lasting reduction in top income shares. Since the turn of the millennium, income concentration in Germany has been on the rise and is today among the highest in Europe. The capital share is consistently positively associated with income concentration, whereas growth, technological change, trade, unions, and top tax rates are positively associated in some periods and negative in others.
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Kessler, Denis, and Andre Masson. "What are the Distributional Consequences of the Socialist Government Policy in France?" Journal of Social Policy 14, no. 3 (1985): 403–18. http://dx.doi.org/10.1017/s0047279400014823.
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AbstractDuring the past four years, French economic and social policy appears to have differed both from the policies followed previously in France and from those of the other industrialized countries. The difference can be judged from the goals pursued, the means used and the results obtained. One of the goals of the socialist government elected in May 1981 was to reduce income and wealth inequalities and to improve the well-being of the poor through an active social and tax policy. This goal was also a means, since these measures — along with an expansionary fiscal policy — were supposed to precipitate economic recovery and to reduce unemployment by stimulating consumption expenditures. Actual developments, however, led to quite a radical change in French macro-economic policy. The fight against inflation and the reduction of internal and external deficits since June 1982 and the search for industrial investment and competitiveness since 1983 have reoriented both social and tax policies.
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Shvets, Alexandra. "Self-employed persons as the actors of tax legal relations: problems of normative legal regulation." Налоги и налогообложение, no. 6 (June 2021): 33–43. http://dx.doi.org/10.7256/2454-065x.2021.6.36978.
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This article examines the normative legal regulation of certain provisions of the legal status of self-employed persons who are the payers of self-employment tax in the Russian Federation. Attention is given to the analysis of such characteristics of the legal structure of this special tax regime as taxpayers, object of taxation and tax rate (in the aspect of social security of the actors of these tax legal relations, alongside other categories of self-employed persons). Assessment is given to the content of Russian legislation considering the legal norms of foreign countries (France, Germany, the United States, and Canada) that have positive and long-term experience in the questions of taxation of income of this category of taxpayers. The conclusion is made on the existence of flaws in naming this special tax regime proposed by the legislator, determination of the range of persons who qualify as the taxpayers in such tax legal relations, and the object of taxation. In view of this, the author formulates the original revision of the norms of the Part 1 of the Article 4 and the Paragraph 4 of the Part 2 of the Article 6 of the Federal Law &ldquo;On Carrying out Experiment on the Establishment of Special Tax Regime &ndash; Self-Employment Tax&rdquo;; as well as advances the opinion on the need to implement the progressive scale of taxation of income of self-employed persons with a mandatory non-taxable minimum and guarantees of their social security on equal terms with other persons engaged in work and professional activity.
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Wyndels, K., J. Dallongeville, C. Simon, et al. "Regional factors interact with educational and income tax levels to influence food intake in France." European Journal of Clinical Nutrition 65, no. 9 (2011): 1067–75. http://dx.doi.org/10.1038/ejcn.2011.73.
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Blanchet, Thomas, Bertrand Garbinti, Jonathan Goupille-Lebret, and Clara Martínez-Toledano. "Applying Generalized Pareto Curves to Inequality Analysis." AEA Papers and Proceedings 108 (May 1, 2018): 114–18. http://dx.doi.org/10.1257/pandp.20181075.
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A generalized Pareto curve is defined as the curve of inverted Pareto coefficients b(p), where b(p) is the ratio between average income or wealth above rank p and the p-th quantile. We present this concept and show how it can be used to better estimate distributions, especially from tax tabulations. By providing a simple decomposition of top shares, we discuss how studying inverted Pareto coefficients can improve the understanding of inequality dynamics. We also show how it helps to better analyze wealth and income concentrations along the distribution, using data for France, Spain, the United States, and China.
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Kotsonis, Yanni. "“Face-to-Face”: The State, the Individual, and the Citizen in Russian Taxation, 1863-1917." Slavic Review 63, no. 2 (2004): 221–46. http://dx.doi.org/10.2307/3185727.
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From the 1860s to 1917, direct taxation provides a window onto the paradoxes of reform in late imperial Russia. The new systems of assessment that culminated in the income tax of 1916 aimed to individualize government in a regime still ordered by legal estate and collective identity; to recognize the autonomy of the individual while disassembling and reintegrating the person by way of comprehensive assessment; and to promote a sense of citizenship, participation, and individual responsibility while still defending autocracy. Yanni Kotsonis suggests that these tensions were borrowed, along with the new techniques of taxation and of government, from European and transatlantic practice, but Kotsonis also locates the distinctiveness of the Russian case in the historical context and the set of ideological premises into which the practices were introduced.
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Kim, Nam Wook, and Dong Ryun Kim. "Legal issues concerning the introduction of environmental tax." National Public Law Review 19, no. 3 (2023): 29–62. http://dx.doi.org/10.46751/nplak.2023.19.3.29.
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Climate change caused by rising greenhouse gases is causing ecological destruction, explosive flames, extreme rainfall and cold weather, earthquakes, tsunamis, wildfires, food shortages, epidemics, etc., and poses environmental risks to the earth and humankind. Countries around the world, including South Korea, have declared carbon neutrality through the Paris Convention and have introduced emissions trading schemes, carbon taxes, energy taxes, and climate change taxes. Recently, in order to introduce a carbon tax, which is the core means of a decarbonized economy and carbon neutrality, South Korea is pending the draft of the basic carbon tax bill and the carbon tax bill in the National Assembly. Therefore, the introduction of an environmental tax is required. There is a view that the concept of the environmental tax includes a contribution under the environmental law, but since the environmental contribution has the characteristics of a quasi-tax as a contribution for the purpose of raising financial resources, if an environmental tax is introduced, the environmental tax must clearly establish the concept of In addition, when strengthening the environmental protection function in the tax system, corporate tax from the standpoint of tax neutrality and fair taxation. income tax. Acquisition tax, property tax, transportation energy and environment tax, tax rationalization plan for automobiles is required. Therefore, clearly establish the concept of environmental tax and respond to climate change. Examine the necessity of introducing an environmental tax from the standpoint of reducing environmental impact, preserving environmental ecosystems, and sustaining development. After grasping the current status of the introduction of environmental taxes in Japan's tax law system, we will examine the environmental tax legislative examples of South Korea, the United States, the United Kingdom, Germany, France, Spain, etc. from a comparative perspective, and seek suggestions for South Korea. In addition, when the environmental tax law is introduced, the legislative limit will be examined within the scope that does not infringe on the fundamental rights guaranteed by the constitution, and proposals will be made to rationalize the current energy tax system, income tax, and corporate tax system. In addition, we will introduce plastic packaging tax, air transportation tax, ecological environmental tax, etc. to promote sustainable development and propose measures to strengthen social relevance to the introduction of environmental tax.
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FROLOVA, Nataliya. "INTERNATIONAL EXPERIENCE IN REFORMING THE INCOME TAXATION SYSTEM IN POST-PANDEMIC AND WAR PERIODS." Economy of Ukraine 2023, no. 10 (2023): 44–57. http://dx.doi.org/10.15407/economyukr.2023.10.044.
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The international experience in reforming income taxation systems in war and post-war conditions is summarized, in particular, approaches to reforming income taxation systems in the USA, Sweden, Denmark, France and Great Britain are compared. Considered examples demonstrate that despite the low budget efficiency of wealth taxes in many countries of Europe and the world (they did not bring considerable budget revenues and at the same time required significant administrative costs), excess profits taxation has been widely practiced for a long time even after the end of the war, in particular, in the post-pandemic period and during the current energy crisis in the EU countries. Main views are systematized regarding individual wealth taxation – not so much as a threat of capital outflow and disincentive for capital investments but as an important component of the tax system, which, coupled with other income and property taxes, contributes to the restoration of wealth distribution equality and minimizes opportunities for tax evasion. Attention is focused on the application of excess profits tax by the EU countries as a temporary European solidarity contribution in response to the global socio-economic crisis caused by the negative consequences of the COVID-19 pandemic and the increase in energy prices due to the military aggression of the Russian Federation. The key requirements that individual wealth tax must meet to be introduced in Ukraine are substantiated. They include establishing a tax exemption threshold at a high level, as well as extending it not only to the residents of Ukraine, but also to the citizens of other countries who own assets on its territory, in order to increase the tax’s progressivity and budgetary efficiency.
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Metz, Robert, Rebecca Riley, and Martin Weale. "Economic Performance in France, Germany and the United Kingdom: 1997–2002." National Institute Economic Review 188 (April 2004): 83–99. http://dx.doi.org/10.1177/00279501041881007.
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We assess the performance of France, Germany and the United Kingdom over the period 1997-2002. Gross and net output per hour worked are considerably lower in the UK than in France and Germany. GDP in France and the UK have grown at the same rates over the period although real national income in the UK has grown considerably faster than in France. Seen from the supply side, French growth is substantially attributable to growth in total factor productivity while in the UK factor inputs are more important. There is, nevertheless, a concern that, at the margin, UK growth may be depreciation-intensive and therefore of poor quality. Germany's growth has been slow because productive inputs have grown only slowly and its weak performance is probably structural rather than cyclical. There does seem to be room for substantial increases in labour input in both France and Germany to be achieved through reform to labour market conditions such as tax rates on low paid workers.
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Koutseva, Elena Aleksandrovna. "Attempting to establish land tax and stamp duty in France in 1787." Samara Journal of Science 10, no. 2 (2021): 167–75. http://dx.doi.org/10.17816/snv2021102206.
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The paper examines the short-term introduction of land tax and stamp duty by Lomnie de Brienne in the summer of 1787 and their further abolition in September 1787. The introduction of new taxes became an urgent need in France in 1787. The huge budget deficit, external debts forced the government to first turn to notables for public approval of the reform plan, and after the failure of this idea, to register through the Paris Parliament in the summer of 1787. Parliamentarians opposed the introduction of these taxes. To combat the deficit, they called for a general economy, cut costs and increased income, demanded the convening of the States General, on which new taxes should be introduced. Discussions and correspondence with the king continued in July and early August 1787. At the royal meeting on August 6, taxes were adopted, but parliament did not obey and advocated their abolition. The king sent parliament into exile. Negotiations began, which led to a compromise: the land tax and stamp duty were canceled, and the term of two twenty was extended until 1792. The work analyzes the stages of the adoption and cancellation of new taxes, highlights the requirements of parliament and the royal administration, studies the land tax edict and the stamp declaration, collection and edict on their cancellation, considers remonstration and decisions of the Paris Parliament, the kings answers and analyzes the reflection of these events in the press and publicism.
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Busch, Christopher, David Domeij, Fatih Guvenen, and Rocio Madera. "Skewed Idiosyncratic Income Risk over the Business Cycle: Sources and Insurance." American Economic Journal: Macroeconomics 14, no. 2 (2022): 207–42. http://dx.doi.org/10.1257/mac.20190019.
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We provide new evidence on business cycle fluctuations in skewed labor income risk in the United States, Germany, Sweden, and France. We document four results. First, in all countries, the skewness of individual income growth is strongly procyclical, whereas its variance is flat and acyclical. Second, this result also holds for continuously employed, full-time workers, indicating that the hours margin is not the main driver; additional analyses of hours and wages confirm that both margins are important. Third, within-household smoothing does not seem effective at mitigating skewness fluctuations. Fourth, tax-and-transfer policies blunt some of the largest declines in incomes, reducing procyclical fluctuations in skewness. (JEL E23, E24, E32, H24, I38, J22, J31)
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Alvaredo, Facundo, Anthony B. Atkinson, Thomas Piketty, and Emmanuel Saez. "The Top 1 Percent in International and Historical Perspective." Journal of Economic Perspectives 27, no. 3 (2013): 3–20. http://dx.doi.org/10.1257/jep.27.3.3.
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The top 1 percent income share has more than doubled in the United States over the last 30 years, drawing much public attention in recent years. While other English-speaking countries have also experienced sharp increases in the top 1 percent income share, many high-income countries such as Japan, France, or Germany have seen much less increase in top income shares. Hence, the explanation cannot rely solely on forces common to advanced countries, such as the impact of new technologies and globalization on the supply and demand for skills. Moreover, the explanations have to accommodate the falls in top income shares earlier in the twentieth century experienced in virtually all high-income countries. We highlight four main factors. The first is the impact of tax policy, which has varied over time and differs across countries. Top tax rates have moved in the opposite direction from top income shares. The effects of top rate cuts can operate in conjunction with other mechanisms. The second factor is a richer view of the labor market, where we contrast the standard supply-side model with one where pay is determined by bargaining and the reactions to top rate cuts may lead simply to a redistribution of surplus. Indeed, top rate cuts may lead managerial energies to be diverted to increasing their remuneration at the expense of enterprise growth and employment. The third factor is capital income. Overall, private wealth (relative to income) has followed a U-shaped path over time, particularly in Europe, where inherited wealth is, in Europe if not in the United States, making a return. The fourth, little investigated, element is the correlation between earned income and capital income, which has substantially increased in recent decades in the United States.
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Burnama, Indrajaya. "ASPEK KEADILAN ATURAN PAJAK INDONESIA DALAM MENGATUR TRANSAKSI EKONOMI DIGITAL: RESPON ATAS INVESTIGASI USTR." Scientax 4, no. 1 (2022): 63–81. http://dx.doi.org/10.52869/st.v4i1.242.
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The growth of digital economy around the world is rapidly increasing. According to a study by Google, Temasek, Bain, and Statista, Indonesia should be the largest digital economic market in South East of Asia. Therefore, a lot of people and industry involved in the digital economy from overseas came to Indonesia. However they are not implementing the tax obligation at all, not only income tax but also value added tax. So, they raise injustice among people and industry involved with digital economy. Until the government released Minister of Finance Decree number 35 Year 2019, Act number 2 Year 2020 and Minister of Finance Decree number 48 Year 2020. However, the regulations were being investigated by United States Trades Representative (USTR). This research discusses implementation of the principle of justice in several tax regulations that regulate digital economic activity as well as current example such as France, Australia and Singapore. This research uses a descriptive qualitative approach. The purpose of this research is to find out the application of the principle of justice in tax regulations related to the digital economy that has been carried out by the government.
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Herzfeld, Mindy. "Debate on the US Tax Reform and the EU ATAD: Can GILTI + BEAT = GLOBE?" Intertax 47, Issue 5 (2019): 504–13. http://dx.doi.org/10.54648/taxi2019051.
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The OECD is moving forward with consideration of a minimum tax as part of its solution to taxation of the digital economy. Part of a template for such a minimum tax may be the version enacted by the United States (US) in 2017 as an expansion of its Controlled Foreign Corporation (CFC) regime, known as Global Intangible Low Taxed Income (GILTI). But the OECD version will undoubtedly be different from the US iteration. It’s likely that it would also include some aspects of a minimum tax being proposed by other OECD members such as Germany and France, namely a tax on outbound payments, in addition to a CFC-type regime. The United States also enacted an outbound minimum tax in 2017, known as Base Erosion Anti-Abuse Tax (BEAT). The two-part minimum tax being pursued by the OECD – a minimum tax based on a CFC regime plus an outbound minimum tax that’s a variation on the BEAT – has been referred to as GLOBE (global anti erosion) (See S. Soong Johnston, Germany, France Explore GLOBE Proposal to Tax Digital Economy, 92 Tax Notes Int’l 782 (2018)). This article summarizes the two features of the US 2017 tax reform (known as the Tax Cuts & Jobs Act (TCJA) (The formal name is The Act to Provide for Reconciliation Pursuant to Titles II and V of the Concurrent Resolution on the Budget for Fiscal Year 2018, Pub. L. No. 115–97.)) that may be incorporated into a global minimum tax, namely GILTI and BEAT, from the perspective of how such provisions might be adapted to work in a global setting. It considers the challenges to taxpayers and policy makers raised by the US law as enacted, and the attempts in recently issued regulatory guidance to address some of these concerns. It compares and contrasts the provisions enacted by the US Congress with a number of parallel European developments, including the EU Anti-Tax Avoidance Directive (ATAD)’s CFC rules and the German royalty deduction barrier. Adaption of the minimum tax components of the Tax Cuts & Jobs Act for worldwide use will require careful understanding of the policy choices, as well as the mistakes made, by the TCJA drafters in designing the regime, in order to ensure that they are not repeated.
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KIRILLOV, A. K., and A. I. SVIREPOV. "BETWEEN THE SCYLLA OF EQUALIZATION AND THE CHARYBDIS OF INEQUALITY: LABOR REMUNERATION ON THE ALTAI RAILWAY IN 1917." LOMONOSOV HISTORY JOURNAL 64, no. 2023, №5 (2024): 108–24. http://dx.doi.org/10.55959/msu0130-0083-8-2023-64-5-108-124.
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The authors examine inequality in an important branch of the Russian economy during the World War I using the materials of one of the large West Siberian enterprises. The study relies on the sources for the first time introduced into the scientific circulation: data from the funds of the tax inspectorate, which are related to the determination of the circle of income taxpayers and their earnings. The advantageous feature of these lists is that they include not only taxpayers (recipients of relatively high income), but all employees of the enterprise in general. Information on the wages of almost 400 employees of the Altai Railroad, from watchman to manager, was used to calculate the decile coefficient. This allows us to expand the field for microhistorical study of inequality by statistical methods through including new industries and new regions. In addition, one of the lists contains information that allows us to raise the question of the need to study additional parameters of inequality in Russia at the beginning of the20th century. It is shown that the income differentiation of railroad workers increases significantly when taking into account their dependents (primarily children), i.e. taking into account family composition can change the interpretation of the degree of income inequality. Another list gives the authors a rare opportunity to examine the wages of railroad employees taking into account individual components of earnings (including salary, military increment, bonuses, payment for extracurricular work). The analysis of change in the decile ratio depending on the above-mentioned payment issues allowed us to prove that one of the weighty additions to the salary reduced the gap between the incomes of the highest and lowest employees, and the other, on the contrary, gave an opportunity to earn more to those who wanted it. Thus, it is demonstrated that one of the wage systems created before the revolution allowed to avoid simultaneously both problems that would become urgent for the new authorities in the 1920s - equalization and excessive inequality.
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Winandy, Jean-Pierre. "Luxembourg: Double Exemption of Real Estate Income Based on the Tax Treaty Concluded Between France and Luxembourg." Intertax 30, Issue 10 (2002): 394. http://dx.doi.org/10.54648/5105713.
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Mus, Mathilde, Hugo Mercier, and Coralie Chevallier. "Designing an acceptable and fair carbon tax: The role of mental accounting." PLOS Climate 2, no. 10 (2023): e0000227. http://dx.doi.org/10.1371/journal.pclm.0000227.
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Despite its potential for curbing greenhouse gas emissions, carbon taxation encounters strong public resistance. However, acceptability depends on how tax revenues are used. We test the hypothesis that mental accounting theory can both explain systematic patterns in citizens’ preferences, such as the support for environmental earmarking, and help design a carbon tax scheme that is both acceptable and fair. Across six experiments conducted in the United Kingdom and in France (Ntotal = 7100), we show that: (a) There is an acceptability boost when the use of tax revenues matches the tax domain thematically (e.g., allocating carbon tax revenues to green projects), as demonstrated by an interaction effect between the tax domain and the expenditure domain on the level of tax support. This result is consistent with the use of a mental accounting heuristic, by which people create mental budgets where the origin of revenues is matched thematically with their domain of use. (b) Carbon tax acceptability varies with the proportion of tax revenues earmarked for green projects. (c) A mixed carbon tax scheme, in which most revenues are earmarked for green projects and the rest is redistributed to low-income households to be spent on sustainable expenses, receives most support among the tested options. We also demonstrate the robustness of the mental accounting heuristic in two ways: by showing that the preference for environmental earmarking of carbon taxes is observed across all relevant subsections of the population, and that mental accounting also appears to shape preferences for health-related earmarking of tobacco taxes, and social-related earmarking of inheritance taxes.
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Zielke, Rainer. "Anti-avoidance Legislation of Mayor EC Member Countries with Reference to the 2014 Corporate Income Tax Burden in the Thirty-Four OECD Member Countries: Germany, France, United Kingdom, and Italy Comp." EC Tax Review 23, Issue 2 (2014): 102–15. http://dx.doi.org/10.54648/ecta2014011.
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Despite continuous instability in the European Community (EC) its mayor countries Germany, France, the United Kingdom, and Italy exhibit continuously economic growth and stability. According to the International Monetary Fund these European countries have - in this order - the highest gross domestic product in the European Community in 2012. In this article anti-avoidance legislation of - according to the gross domestic product - the four most important EC countries will be reviewed with reference to the tax differential to the thirty-four OECD Member Countries. The pivotal question is, therefore, to what extend can internal tax planning with mayor European countries be optimized by inclusion of anti-avoidance legislation. This article outlines the objectives and concepts of international tax planning with regard to anti-avoidance legislation and provides an overview of the concepts, laws and rules of anti-avoidance legislation in mayor EC Member Countries. After that the advantages and strategies of international tax planning with regard to anti-avoidance legislation in mayor EC Member Countries are deducted where an overview on anti-avoidance legislation of mayor EC Member Countries is provided - also with regard to new tax legislation - and locations for subsidiaries and for parent companies are reviewed. Finally, the concluding remarks are presented. Transfer pricing will not be reviewed here.