Thèses sur le sujet « Assessment of taxation »

Includes bibliographical references.
This dissertation attempts to critically analyse the tax on capital gains as an addition to South Africa's fiscal framework. The method of the analysis involves the collation of international research on the effects of capital gains tax on the economies, financial markets, labour markets and revenue authorities of various countries. The focus is on the economic and fiscal areas directly relating to the long-term economic and fiscal policy goals of the South African government. These goals, as well as the justification given by the South African Department of Finance and the South African Revenue Service for the introduction of the capital gains tax are presented in the literature review section of this study. Research of international tax practices indicates that the taxing of capital gains has a depressive effect on capital formation, labour productivity, foreign and domestic direct investment, business creation, entrepreneurship and taxpayer equity. In addition, the introduction of such a tax has no proven growth effects on governmental revenue, and does not significantly dissuade tax avoidance schemes using arbitrage measures. By applying the globally observed effects of the capital gains tax to the long-term policy goals mentioned above, I conclude that the capital gains tax does not assist in the achievement of the economic and fiscal policy goals of the South African government, neither in the short- nor the long-term. Conversely, the capital gains tax acts as a countermeasure to the achievement of the said goals.

Mestrado Bolonha em Economia Monetária e Financeira
The role of the State in economies has changed in recent years. The public sector's challenge is to reconcile a wide range of new services using the lowest possible costs. Thus, understanding how governments raise and set their revenues is highly important. The effectiveness with which tax agencies carry out their tasks has always been seen as a priority by governments. Tax administrations play an essential role in all countries, so its study is of extreme interest. They must provide quality services to taxpayers to voluntarily enforce their civic duty regarding tax legislation. Taxation is not a technical issue but purely political and philosophical that allows societies to function correctly. Progressive tax systems have long been an element of study by economists. Its creation is based on equality and proportionality concerning the tax burden. We will try to find the possible relationship between the progressiveness of taxes and the efficiency of the tax authorities. That is, to what extent a progressive tax system may or may not alleviate the costs of tax collection activity and thus promote greater prosperity and, ultimately, efficiency. Our findings suggest that countries with inefficiency in direct taxes make progressive efficiency impossible.
info:eu-repo/semantics/publishedVersion

Thesis (Ph. D.)--Ohio State University, 2004.
Title from first page of PDF file. Document formatted into pages; contains x, 160 p.; also includes graphics Includes bibliographical references (p. 150-160).

Sustainability of the aviation industry, as any other industry, depends on the elasticity of demand for the product and profitability through minimising operating costs and hence assessing and understanding the interdependency and effects of environmentally optimised solutions and emission mitigation policies, is paramount. The contribution to knowledge, from this research, is the development and application of assessment methodologies to better understand the effects that future potential environmental taxation may have on the adaptation of optimised “greener” operations and novel technologies. These studies are undertaken using a Techno-economic Environmental Risk Assessment approach (TERA). The first methodology introduced to assess optimised operation methods (based on operating cost analysis), demonstrated that carbon taxation has limited effect if applied in isolation. Increasing it to extreme levels, apart from resulting in an increase in operational costs and raising governmental revenues, may not necessarily result in influencing an airline operator’s operational strategy to move to greener solutions. Instead, an application of a taxation level, commensurate to global standards, coupled with an improved air traffic management system, would allow aircraft to fly closer to their design efficiency and hence aid in reducing the environmental impact. The second methodology introduced (based on an operating and investment cost analysis) allows the assessment of the economic viability of a new technology in comparison to a conventional technology, when considered in terms of relative increase in acquisition price and maintenance costs, for various emission taxation and fuel price scenarios. A study undertaken as a ‘proof of concept’, comparing a Counter Rotating Open Rotor (CROR) aircraft with a conventional aircraft, indicates that at a current fuel price and no carbon taxation, despite being demonstrated as a highly fuel efficient technology, a relative increase in acquisition price and maintenance costs in comparison to the conventional aircraft, could render the CROR technology, economically unviable. The work further demonstrates that for the CROR technology to be economically beneficial, a simultaneous introduction of emission taxes may be required. The study shows that in order to achieve lower environmental impact, the implementation of taxation with the introduction of greener technologies will evidently increase the cost of civil aviation operation. This research subsequently identifies the following questions, more of a ‘political and socio-economic nature’, to consider as part of further work.  If taxes above the global industry standards are introduced for the aviation industry, and they are higher in comparison to those applied on some other carbon intensive sectors, will it raise questions on equity of treatment?  If taxation is introduced, airline operators and the ticket price paying passengers being amongst the key stakeholders in the aviation industry, will such high pricing as demonstrated be practical for long term sustenance?  Will policies be driven by the fact that they will be aimed as a trade-off between achieving global sustenance of the industry and achieving environmental gain?  Will high taxation as demonstrated, have global acceptance or will it have to be compromised, based on the growth potential or GDP of a country/ region?

My dissertation is about the review made by Revenue authorities of the unlawful assessments of taxation. It deals with the nature and the aims of the power of review, and the public interest for a right and impartial taxation. The dissertation also deals with the possibility for taxpayers to defend themselves against the unlawful review made by the authorities, which do not avoid the wrong assessments or do not even review their previous acts although they are unlawful.

This thesis focuses on two case studies in order to provide evidence relating to the central hypothesis that effective policy analysis can require a wider approach than that offered by Economics alone and that an interdisciplinary analysis can lead to further insights into the relevant issues. The main case study involves self-assessment for income tax. It is argued that a cost-benefit type study of current administrative and compliance costs is insufficient to analyse the desirability of operating a self-assessment system. The work that follows therefore analyses the UK tax system and its administration in order to understand the development of the present system and what it is required to do. It makes comparisons with the Swedish tax system and draws on the findings of two important publications, the Report of the Meade Committee and The Reform of Personal Taxation. The research goes on to use management methods to analyse the future likely enviromnent in which the tax system will have to operate. It includes important related issues such as tax compliance where it is shown that taxpayer compliance is influenced by psychological and sociological as well as purely economic factors. The second case study is concerned with economic decision-making. The research presented here on female economic decision-making similarly takes a wider approach to policy analysis. It does this by locating the decision-making process in a social, family, context rather than only as a result of the independent actions of utility maximising individuals, which would be the more normal mainstream economic approach. It finds that social and gender-related factors are also important variables in economic decision-making in households. The overall conclusion is that to achieve a fuller understanding of human economic behaviour and to develop appropriate policy solutions to important questions, economic analysis needs to be supplemented by a wider approach drawing on other disciplines as appropriate.

A new revised prudential regulatory regime for insurers will be introduced in order to align the South African insurance industry with international standards. This regime, called Solvency Assessment and Management, is based on its European counterpart, which is known as Solvency II. This study starts off by investigating and comparing Solvency II, to be implemented in the United Kingdom, with Solvency Assessment and Management, to be implemented in South Africa, identifying a number of similarities between the regimes. The taxation of long-term insurers in both jurisdictions is then investigated, but no similarities are identified. The above prepares the ground for the main purpose of the study, which is to identify the impact of Solvency Assessment and Management on the taxation of long-term insurers in South Africa. This study identified the impact as effecting a change in the current basis used for the valuation of policyholder liabilities, which will cause a decrease in the value of liabilities, and consequently an increase in underwriting profit. The impact of this change is illustrated, and there are clear indications that there is a need to amend current income tax legislation or the directive used to determine the value of liabilities. Two options for amendments are identified but no changes to legislation are expected before 2015.
Dissertation (MCom)--University of Pretoria, 2013.
lmchunu2014
Taxation
unrestricted

Concern that high property taxation of agricultural land encourages its conversion to nonagricultural uses has led to the adoption of use-value taxation practices. Use-value taxation has had mixed results as a deterrent to the conversion of agricultural and open space land. It has been argued that use-value taxation does not succeed in retaining open space along the rura1-urban fringe (Stocker 1975; Ferguson), and further that such programs may actually lower the community's property tax base significantly (Tiebout; Anderson 1993). Additionally, when land is taxed by its usevalue rather than market-value, the local tax base declines curtailing local public services and consequently reducing the attractiveness of the community for residential, commercial and industrial land uses (Abeyratne and Johnson, Bickerdike, Netzer, Oates).

This study seeks to determine the fiscal impacts of use-value taxation and incurred and immediate revenues generated by a particular land use project. By comparing the net impact on the property tax rate of different land uses, the effectiveness of land use taxation policies for communities can be determined. The fiscal impact of alternative land uses are measured using The Virginia Impact Projection (VIP) model. The empirical models employed are based on a static cross-sectional econometric analysis of Virginia counties initially developed by Johnson and Keeling and updated for the current analysis using more recent data. The empirical equations are used to construct a fiscal impact assessment (simulation) model. The simulation model allows the comparison of impact and baseline scenarios developed using alternative land uses.

It was found that the impact offarmland enrollment in use-value assessment programs is not as large when net impacts are considered rather than sole consideration of the direct property tax revenue changes.

Master of Science

E-tolling was recently implemented on roads in Gauteng, South Africa. This gave rise to a great deal of protest by road users and a court battle between the South African National Roads Agency (SANRAL) and the Opposition to Urban Tolling Alliance, a body representing road users. The e-tolling system was criticised at various levels and on numerous grounds, some financial and others appearing to be emotional. This thesis attempted to analyse the various grounds for objection against the system, the main goal of the research being to analyse e-tolling in Gauteng to ascertain whether or not the introduction of e-tolling was justified or whether an alternative method of taxation to pay for the upgrading of Gauteng roads would have been more cost-effective. Secondary data in the form of documents from multiple sources was used in the analysis, including an Economic Impact Assessment that was one of the key inputs into the decision to introduce e-tolling. It was found that there are multiple problems plaguing the e-toll system and e-tolling is not the most cost-effective taxation method of paying for Gauteng roads. Using a fuel levy or general tax revenue available to the National Treasury were both found to be more cost-effective methods as they would have achieved the same result (repairing and upgrading specific Gauteng roads), at a cost of R20,0913 billion less than e-tolling. It was suggested that the best taxation method/s to pay for the roads would have been using a fuel levy and general tax revenue as the primary funding methods, with vehicle licensing fees and long distance toll roads as secondary methods to aid the primary methods.

The purpose of this study is to shed more light on whether the investment tax credit is effective in stimulating capital investment. The sample includes 104 local cooperatives. The majority of the data was collected from the files of the St. Paul, Minnesota, Bank for Cooperatives. The study has a single purpose of determining whether the changes to the Internal Revenue Code in the Revenue Tax Act of 1978 had an effect on the capital expenditure levels of farm supply cooperatives. In 1978 the investment tax credit became fully available to cooperatives. Previous abatement rules were abolished, and unused credit was then passed through in full to the cooperative membership. The research model employed is a pooled time-series and cross-sectional approach, and includes data for years 1975 through 1983. In addition to capital expenditure data, the company-specific variables are debt/asset ratio, local margin, and net margin. Economic variables are a net interest-inflation rate factor, cash receipts from farming, and loan volume of banks for cooperatives. Also included are dummy variables 0 and 1, trend variables 1-9, and interaction variables for all the main-effects variables.

Syftet med den här studien är att beskriva och analysera hur ett småhus ålder kan påverka marknadsvärdet och taxeringsvärdet för en småhusfastighet samt hur den svenska taxeringsmodellen tar hänsyn till hur ett småhus ålder påverkar värdet. Målet är att ge förslag på hur ett småhus ålder kan behandlas vid fastighetstaxering i Sverige. Ett småhus definieras som en byggnad inrättad till bostad för en till två familjer och en småhusfastighet utgörs av ett småhus plus dess tomtmark. Vid fastighetstaxering av småhusfastigheter i Sverige bestäms ett byggnads- och ett tomtmarksvärde som sedan slås ihop till ett taxeringsvärde för småhusfastigheten, taxeringsvärdet ska motsvara 75 % av marknadsvärdet två år före taxeringsåret. Byggnadsvärdet respektive tomtmarksvärdet bestäms utifrån olika värdefaktorer, en av dem är värdefaktorn ålder vilket anges som ett värdeår ämnat att uttrycka en byggnads återstående ekonomiska livslängd. Metoder som har använts i studien är en litteraturstudie som granskat tidigare forskning inom ämnet samt lagstiftning och facklitteratur. En kvantitativ undersökning av småhus och köp i Gävle kommun har genomförts för att skapa en generell bild av hur ett småhus ålder påverkar småhusfastigheters taxeringsvärde samt en generell bild av när taxeringsvärdet är svårbedömt på grund av ett småhus ålder. För att erhålla en djupare förståelse för hur ett småhus ålder kan påverka småhusfastigheters marknadsvärde genomfördes en kvalitativ undersökning av ett fåtal småhus. Resultatet av litteraturstudien visar att de åldersrelaterade variabler som kan påverka ett småhus marknadsvärde är: depreciering, läge, byggnadskonstruktion, underhåll samt vintage-effekt. De åldersrelaterade variabler som den svenska taxeringsmodellen tar hänsyn till är: depreciering, åldersinverkan i förhållande till läge samt jämkning av värdeår. Litteraturstudien samt den kvantitativa och den kvalitativa undersökningen tyder på att det finns vissa brister i hur åldersfaktorn hanteras vid fastighetstaxering i Sverige, främst när det gäller äldre byggnader. Eftersom de båda undersökningarna genomfördes endast med småhusfastigheter i Gävle kommun är dock resultatet inte direkt applicerbart på hela Sveriges småhusbestånd. Ändock drogs slutsatsen att det anses motiverat att ge förslag på hur den svenska taxeringsmodellen kan behandla åldersfaktorn vid fastighetstaxering av småhus. Förslaget innefattade de åldersrelaterade variablerna: depreciering, läge, underhåll, köparpreferenser samt byggnadskonstruktion.

This study examines the influence of tax compliance costs on non-compliance behaviour, taken together with the business characteristics and managerial perceptions of corporate taxation. The study focuses on corporate Small and Medium Enterprises (SMEs) in Malaysia under the Income Tax Self-Assessment System (SAS). This is the first study on corporate income tax compliance in the Malaysian context and among the first to integrate tax compliance costs, tax attitudes and the likely compliance behaviour of corporations, both in Malaysia and internationally. Thus it makes a significant contribution given this dearth of international literature on corporate tax compliance.The study adopts a traditional large-scale postal survey questionnaire technique that has been employed extensively by studies of both tax compliance and compliance costs studies internationally. Specifically, estimation of tax compliance costs largely follows the usual technique used by Pope, the ‘father’ of tax compliance costs studies in Australia and Asia. This estimation method was first established by Sandford, the ‘grandfather’ of modern tax compliance costs studies, and has been globally employed with some modification to the local context. On the other hand, tax attitudes and the likely compliance/non-compliance behaviour of SMEs are measured from a business managerial or respondent perspective. The above primary postal survey, as well as two additional surveys—a web survey of SMEs and a postal survey of tax professionals— have been undertaken as a measure of consistency of the primary postal survey.The income tax compliance costs for Malaysian SMEs are estimated at RM9,295 per company, amounting to RM1,084 million in aggregate for the 2006 tax year. The findings of this study demonstrate that the average income tax compliance costs of SMEs under the SAS have decreased significantly by 58 percent in absolute terms. Despite this, the increasing composition of both external costs and computational costs, by 16 and 15 percent respectively, reveals that the role of tax professionals and routine tax works have become substantially greater under the SAS regime. The figure for compliance costs relative to tax revenue of eight percent is found to be similar to a pre-SAS Malaysian study, and is also within the international range overall. As for the offsetting benefits, the value of tax deductibility is estimated to be almost RM1,700 per SME company, RM196 million in aggregate, or around 18 percent of the compliance costs, thus giving average net compliance costs of RM7,595 or RM888 million in total.The current study provides evidence of the influence of tax complexity and probability of tax audit on corporate SME tax non-compliance in Malaysia. Compliance costs, in particular, together with two business characteristics, i.e. business size and tax level, and the managerial perceptions about tax fairness and the Inland Revenue Board (IRB) relationship, are found not to influence corporate tax non-compliance. On the other hand, the effect of the remaining four variables, i.e. business length, sector, tax rate and tax incentives, is inconclusive. In terms of international comparisons, the effects of business size on previous corporate tax compliance are mixed, but the business sector was found to influence corporate tax compliance.Regarding tax compliance costs, the need to recognise the presence and regressivity of tax compliance costs upon SMEs should be, at this stage, recognised at the national level. Further, at a later stage, such issues should be systematically considered and assessed for any major change in tax policy. Findings regarding tax complexity suggest that the IRB should continue their tax simplification measures in a more comprehensive manner to significantly minimise the compliance burden for all business taxpayers, of any size. In terms of tax auditing, the IRB may want to increase substantially the magnitude of such activity, and should utilise such information effectively to lift taxpayers’ levels of awareness about the likelihood of their businesses being selected for a tax audit.Finally, it is acknowledged that there are several limitations of the current study, including those usually associated with self-reporting mail surveys, which may limit the interpretation of the current findings. Despite this, the study makes a significant contribution given the limited number of studies in the field of corporate tax compliance and tax compliance costs studies, particularly for Malaysian SMEs. Future research into this area, including several extensions of this study, could make further valuable contributions in this area.

Sparandedirektivets syfte är att effektivisera beskattningen av ränta på sparande inom EU genom att räntan ska beskattas i betalningsmottagarens hemviststat. Direktivet gäller endast fysiska personer och gränsöverskridande räntebetalningar. Syftet ska uppnås genom ett utbyte av information medlemsstaterna emellan. I stället för att utbyta information kan en medlemsstat välja att ta ut källskatt på ränta och vidarebefordra en viss del av källskatten till betalningsmottagarens hemviststat. De svenska bankernas kontrolluppgiftsskyldighet för begränsat skattskyldiga sparare har i och med direktivets införande utvidgats. Bankerna skickar uppgifterna till Skatteverket som i sin tur vidarebefordrar dem till behörig myndighet i spararens hemviststat.

Direktivet innehåller ett undantag, de minimis-regeln, som innebär att medlemsstaterna om de vill får undanta vissa ränteinkomster som härrör från fondföretag. Syftet är att undanta aktiefonder som måste investera i fordringar av likviditetsskäl. Regeringen har valt att inte införliva undantaget i svensk lag. Detta medför enligt vår åsikt en konkurrensnackdel för de svenska fondbolagen. På grund av Regeringens beslut måste dessa bolag, för att kunna sälja sina fonder inom EU, kunna redovisa hur stor del av en utdelning som hänför sig till ränta. Kan de inte göra detta betraktas hela beloppet som ränta och omfattas därmed av kontrolluppgiftsskyldighet.

Sparandedirektivet har implementerats i svensk lag genom en paragraf i lagen om självdeklarationer och kontrolluppgifter (LSK) som stadgar att direktivet gäller som svensk lag. Utöver detta har ett antal ändringar införts i LSK. Vi anser att implementeringen kan strida mot direktivet som föreskriver att medlemsstaterna ska anta de lagar och förordningar som krävs för att uppfylla direktivets föreskrifter. Vi anser inte att LSK på ett tillfredsställande sätt har anpassats till direktivet eftersom LSKs regler ibland överlappar direktivet och ibland motsäger det. LSK innehåller två undantag från kontrolluppgiftsskyldigheten. Dessa undantag strider mot direktivet som inte innehåller några dylika undantag. Vi anser dock att undantagen är rimliga eftersom de undantar konton utan betydelse för informationsutbytet och att liknande undantag bör införlivas i direktivet.

Med anledning av sparandedirektivets införande har de svenska bankerna, i rollen som betalningsombud, föranletts merarbete och kostnader. Kostnaderna har uppstått bland annat då bankerna har ändrat sina datasystem för att kunna uppfylla direktivets kontrolluppgiftsskyldighet. De har även fått komplettera sin information om begränsat skattskyldiga kunder.

Skatteverket är den behöriga myndigheten i Sverige och ska således vidarebefordra de uppgifter om personer som är begränsat skattskyldiga i Sverige som lämnas av betalningsombuden. Eftersom Sverige sedan tidigare har ett väl utbyggt kontrolluppgiftssystem och har deltagit i informationsutbytet inom OECD har sparandedirektivets införande inte medfört särskilt stora kostnader för Skatteverket.

Sparandedirektivet förväntas leda till ökade skatteintäkter för de stater vars obegränsat skattskyldiga personer placerar sina tillgångar utomlands. Emellertid finns det risk för att dessa personer placerar sina tillgångar i andra typer av sparande eller placerar tillgångarna i stater som inte omfattas av direktivet för att undgå beskattning. Vi anser därför att det finns risk för att sparandedirektivet blir ett slag i luften.

The aim of the Savings Taxation Directive is to ensure an effective taxation of income from savings in the form of interest payments within the EU. This shall be done through taxation of the interest payment in the Member State where the beneficial owner, the saver, has his residence. The directive is only applicable on individuals and on cross-border payments. The aim shall be achieved through an exchange of information between the Member States. Instead of exchanging information, a Member State can choose to levy a withholding tax. A certain amount of that tax shall be transferred to the Member State of residence of the beneficial owner. The obligation for Swedish banks to forward statements of earnings concerning foreign savers has been extended through the directive. The banks sends the information to the Swedish tax authority which then forwards the information to the competent authority in the savers state of residence.

The directive contains an exception, the de minimis rule, that states that Member States can choose to exempt certain interest payments deriving from Undertakings for the Collective Investment of Transferable Securities (UCITS). The aim of the exception is to give the Member States a possibility to exclude undertakings which invest mainly in equity but which must hold some debt for liquidity purposes. The Swedish Government has chosen not to implement the exception into Swedish law. In our opinion, this leads to a competitive disadvantage for Swedish UCITS. Due to the Governments’ decision, the Swedish UCITS must, in order to be able to sell their products within the EU, be able to show the interest part of a dividend. If this cannot be done, the entire amount is considered as interest and must be reported as such.

The directive has been implemented into Swedish law through a paragraph in the Law of Self Assessment and Statement of Earnings. It states that the Savings Taxation Directive shall be applied as Swedish law. Besides the implementation, some parts of the law have been changed. We think that the implementation may be in breach of the directive, which states that Member States must pass laws and decrees necessary to fulfill the regulations in the directive. We do not think that the Swedish law has been adjusted to the directive in a sufficient way since the Swedish law sometimes overlap the directive and sometimes contradict it. The Swedish law contains two exceptions from the obligation to give statements of earnings. These exceptions breach the directive since the directive does not contain any exceptions of this kind. However, we think that the exceptions are reasonable since they exempt bank accounts which are of no importance for the exchange of information stated in the directive. Similar exceptions should therefore in our opinion be included in the directive.

The implementation of the Savings Taxation Directive has caused the Swedish banks, in their role as paying agents, supplementary work and costs. The costs have occurred when the banks have had to adopt their computer systems in order to fulfil the criteria in the directive. The banks also had to complete their information about foreign savers who are liable to tax in Sweden.

The Swedish tax authority is the competent authority in Sweden and shall therefore report the information, concerning foreign tax payers, that is forwarded by the paying agents. Sweden had, even before the implementation of the directive, a well functioning system for statements of earnings. The state also participates in the exchange of information that takes place within the OECD. Therefore, the implementation of the directive has not caused any costs of importance for the Swedish tax authority.

It is expected that the Savings Taxation Directive will give rise to increased tax revenues for the Member States whose tax payers invest abroad. However, there is a risk that these savers invest in other products or transfer their assets to states that are not within the scope of the directive in order to avoid taxation. Because of this, we think that the Savings Taxation Directive might be a waste of effort.

Made available in DSpace on 2016-04-26T20:26:00Z (GMT). No. of bitstreams: 1 Clayton Eduardo Prado.pdf: 531979 bytes, checksum: e2b1fd0112e75ea983f01de2f00c951a (MD5) Previous issue date: 2007-10-25
The study concerns about the inheritance taxation and intends to construct its basic rule of incidence, from the examination of the constitutional rules that discipline this tax, identifying the two equations that compose it: the antecedent (hypothesis tax), describing its material, spatial and temporal criteria; and the consequence (legal relationship tax), identifying its personal (active and passive subject) and quantitative (aliquot and taxable base) criteria. At the second moment, it examines the Law n. 10.705/2000 of the São Paulo State to verify if it is compatible with the constitutional profile of this tax. Further on, the São Paulo legislation comes back to be the focus, to analyse the tax exemption phenomenon. Later, it concerns about the tax assessment, evidencing the peculiar aspects of this tax. The final topic intends to face two intricate questions: the decadence and the prescription of the ITCM
O trabalho trata do imposto sobre transmissão causa mortis de quaisquer bens ou direitos (ITCM) e tem entre seus objetivos construir a sua regra-matriz de incidência, a partir do exame das normas constitucionais que disciplinam esse tributo, identificando as duas equações que a compõem: o antecedente (hipótese tributária), descrevendo os seus critérios material, espacial e temporal; e o conseqüente (relação jurídica tributária), identificando os seus critérios pessoal (sujeitos ativo e passivo) e quantitativo (base de cálculo e alíquota). Construída a regra-matriz de incidência tributária, examina as normas da Lei n. 10.705/2000 do Estado de São Paulo, objetivando verificar em que medida elas são compatíveis com o perfil constitucional desse tributo. A seguir, a legislação paulista volta a ser o foco, com a finalidade de se analisar o fenômeno da isenção do imposto sobre transmissão causa mortis. Posteriormente, trata do lançamento tributário do ITCM, constatando os traços peculiares a esse tributo, sobretudo quando apurado no âmbito de processos judiciais. O tópico final visa enfrentar duas intrincadas questões: a decadência e a prescrição do ITCM, onde se verifica, igualmente, que esse imposto possui singularidades decorrentes da sua forma de apuração

碩士
逢甲大學
土地管理學系
87
ABSTRACT Taiwan is experiencing problems of underestimate and unequal assessment for the land value tax. Ratios of land value assessment and market value may vary substantial across counties and cities. This study incorporates the method used by Paglin and Fogarty (1972) and the coefficient of dispersion to measure the uniformity, vertical inequity, and horizontal inequity of the land value assessment data of 21 counties in Taiwan. We find that there exists significant horizontal inequity among various counties. Such results are useful in understanding local governments* tax base management and tax efforts on land value taxation.

碩士
樹德科技大學
經營管理研究所
101
This study is to resolve matters related to assess performance of Inspectorate of General Department of Taxation affecting tax inspection activities in Vietnam. Data is collected on basis of studying published macro-economic reports, Hanoi economic reports, and financial statements in the last 3 years and organizational structure of tax sector as well as operating situation, working process of tax inspectors in Hanoi. Then, the data is analyzed, synthesized in combination with consulting experts and comparison with current applied models. Quantitative research methodology is used. The research only focuses on an advisory unit in General Department of Taxation; hence, it cannot be applied to other administrative and professional units which do not belong to tax sector. 　The research findings shows that job assessment, colleague, nature of the job of inspectors at General Department of Taxation in Vietnam are not high although reasonable work allocation, clear responsibility and right division has helped to give the job the right person and laid favorable conditions for job examination and assessment. Moreover, paying salary according to the coefficient stated in provisions on salary of the law on public employee helps to prevent competition and dissatisfaction in colleague relation. Income is necessary to formulate policies which take more care of the life of inspectors in General Department of Taxation, especially from spiritual perspective. Because according to the research findings, income satisfaction level is similar to job satisfaction level tax inspectors. Income satisfaction level of tax inspectors at General Department of Taxation in Vietnam is 3.2596, which is lower than the overall satisfaction level of the inspection sector (3.4119) and is the factor with the lowest mean satisfaction level. Leader is necessary to pay more attention to life of inspectors, listen to their wish and need as well as acknowledge the talents, to encourage inspectors to propose initiative to improve working method. At the same time, inspector’s contribution should also be recognized through salary and bonus policies, creating favorable conditions for promotion of talented officers with great contribution in order to create motivation for them as well as encouraging all other inspectors to take more efforts. Because, according to the findings, satisfaction level on leader is similar to job satisfaction level of inspectors at General Department of Taxation. Satisfaction level on leader of inspectors at General Department of Taxation in Vietnam is 3.3750, which is lower than the overall satisfaction level of 3.4119, in which components have lowest satisfaction level are: “ Leaders listen to opinions of employees” and “Leaders acknowledges talent and contribution of employees”. 　Main contribution of this research is to provide an empirical research on development of a system of criteria to assess officers at a State agency. This stimulates our understanding on a procedure to develop a system of criteria to assess officers in public agencies. This research shows that a system of criteria to assess the State officers needs to be established on basis of a set of distributed criteria in groups of criteria covering activities of officers at the Inspectorate, General Department of Taxation. Especially, this system of criteria needs to be developed on a modern theoretical basis with contemporary theories on the State officers’ behavior as a human being rather than a variable. Therefore, this research has policy implication for administrative reform program, especially streamlining administrative system in Viet Nam. In order to have a basis for streamlining administrative system, officers need to be assessed basing on quantitative and qualitative criteria of high reliability so that officers who work inefficiently and in turn hinder the system development are removed from the State management system.

M.Com. (South African and International Taxation)
International tax treaties are unique bilateral negotiations effectively breaking down the barriers of international trade while aiming to eliminate double taxation and prevent fiscal evasion. The implementation of these negotiated tax treaties is a matter of domestic law, once concluded a contracting state is free to use domestic legislation to tax the income allocated through the these tax treaties. There is however, no external enforcement of these agreements and as a result disputes occur. The remedy proposed by both the OECD MTC and the UN MTC is what we know as MAP. MAP is a non-binding, non-compulsory dispute resolution mechanism developed in the early 20th century. Even though many jurisdictions remain of the view the MAP is a successful method of dispute resolution, others feel that it has significant shortcomings as outlined by the JWG established by the OECD in 2003. As a result of the work done by the JWG and in an attempt to address some of the insufficiencies of the MAP the OECD introduced additional articles to the MTC including guidelines on non-binding arbitration. The UN subsequently introduced similar guidelines in its MTC. The introduction of mandatory arbitration into both these MTCs is the most significant development in the resolution of international tax disputes. However, the increased complexity and volume of international trade undoubtedly results in tax implications that are not currently addressed in tax treaties or conventions. Differences in the interpretation of the underlying facts of those trade transactions may lead to a host of international tax disputes, often resulting in juridical double taxation. With MAP being the only remedy available, this study aims to determine whether or not the MAP in its current form, is an effective international dispute resolution mechanism or whether further developments are still required.

This thesis provides empirical evidence to assess the long term contribution of the B.C. forest industry to the provincial economy. Estimates of resource rent are constructed to measure the direct contribution of the resource to provincial income and growth. Measures of rent are constructed for a firm level sample (1906-76) and at an industry level (1918-92). The figures for rent are used to generate estimates of the share of provincial income measures directly attributable to the industrial exploitation of the province's forests. While there were periods during which the direct contribution to provincial income and its growth was nontrivial, in general the growth of forest industry rent did not drive overall economic growth but rather lagged behind. Rent was low on average and volatile during the years before W.W.II, rose rapidly from roughly 1940-51, then declined unevenly. To investigate the forces which underlie both the broad trends and the variability in rent, a stylized model of the forest industry is applied in an empirical analysis. Broad changes in aggregate rent were the result of changes in rent per unit of B.C. timber. The rapid increase in rent coincided with a marked rise in the price of forest products. The secular decline resulted from the combination of a falling output price and rising costs. An investigation of real harvesting costs indicates that depletion played a role in this increase. The variability of rent is also explored and found to be most strongly influenced by factors reflecting market risk which the B.C. industry could not diversity away from. The rent measures may not capture the full impact of the forest industry, so the industry's potential role as a leading export sector is also examined. The possibility of a stable long term link between forest exports and provincial income is investigated using cointegration tests. B.C. forest exports and G.D.P. are not cointegrated; their levels axe not linked in a deterministic way in the long run. A bivariate VAR, is used to examine the short run interaction between the growth of forest exports and provincial G.D.P. The results do not strongly support the view that the forest industry acts as a leading export sector in the provincial economy.

This thesis is concerned with a new computational study of optimal investment decisions with proportional transaction costs or capital gain taxes over multiple periods. The decisions are studied for investors who have access to a risk-free asset and multiple risky assets to maximize the expected utility of terminal wealth. The risky asset returns are modeled by a discrete-time multivariate geometric Brownian motion. As in the model in Davis and Norman (1990) and Lynch and Tan (2010), the transaction cost is modeled to be proportional to the amount of transferred wealth. As in the model in Dammon et al. (2001) and Dammon et al. (2004), the taxation rule is linear, uses the weighted average tax basis price, and allows an immediate tax credit for a capital loss. For the transaction costs problem, we compute both lower and upper bounds for optimal solutions. We propose three trading strategies to obtain the lower bounds: the hyper-sphere strategy (termed HS); the hyper-cube strategy (termed HC); and the value function optimization strategy (termed VF). The first two strategies parameterize the associated no-trading region by a hyper-sphere and a hyper-cube, respectively. The third strategy relies on approximate value functions used in an approximate dynamic programming algorithm. In order to examine their quality, we compute the upper bounds by a modified gradient-based duality method (termed MG). We apply the new methods across various parameter sets and compare their results with those from the methods in Brown and Smith (2011). We are able to numerically solve problems up to the size of 20 risky assets and a 40-year-long horizon. Compared with their methods, the three novel lower bound methods can achieve higher utilities. HS and HC are about one order of magnitude faster in computation times. The upper bounds from MG are tighter in various examples. The new duality gap is ten times narrower than the one in Brown and Smith (2011) in the best case. In addition, I illustrate how the no-trading region deforms when it reaches the borrowing constraint boundary in state space. To the best of our knowledge, this is the first study of the deformation in no-trading region shape resulted from the borrowing constraint. In particular, we demonstrate how the rectangular no-trading region generated in uncorrelated risky asset cases (see, e.g., Lynch and Tan, 2010; Goodman and Ostrov, 2010) transforms into a non-convex region due to the binding of the constraint.For the capital gain taxes problem, we allow wash sales and rule out "shorting against the box" by imposing nonnegativity on portfolio positions. In order to produce accurate results, we sample the risky asset returns from its continuous distribution directly, leading to a dynamic program with continuous decision and state spaces. We provide ingredients of effective error control in an approximate dynamic programming solution method. Accordingly, the relative numerical error in approximating value functions by a polynomial basis function is about 10E-5 measured by the l1 norm and about 10E-10 by the l2 norm. Through highly accurate numerical solutions and transformed state variables, we are able to explain the optimal trades through an associated no-trading region. We numerically show in the new state space the no-trading region has a similar shape and parameter sensitivity to that of the transaction costs problem in Muthuraman and Kumar (2006) and Lynch and Tan (2010). Our computational results elucidate the impact on the no-trading region from volatilities, tax rates, risk aversion of investors, and correlations among risky assets. To the best of our knowledge, this is the first time showing no-trading region of the capital gain taxes problem has such similar traits to that of the transaction costs problem. We also compute lower and upper bounds for the problem. To obtain the lower bounds we propose five novel trading strategies: the value function optimization (VF) strategy from approximate dynamic programming; the myopic optimization and the rolling buy-and-hold heuristic strategies (MO and RBH); and the realized Merton's and hyper-cube strategies (RM and HC) from policy approximation. In order to examine their performance, we develop two upper bound methods (VUB and GUB) based on the duality technique in Brown et al. (2009) and Brown and Smith (2011). Across various sets of parameters, duality gaps between lower and upper bounds are smaller than 3% in most examples. We are able to solve the problem up to the size of 20 risky assets and a 30-year-long horizon.

The global financial environment is constantly and rapidly shifting. This has resulted in changes to the International Financial Reporting Standards (IFRS). In support of the developments in the global business environment and the swift changes in IFRS, the local financial regulators have had to follow with supporting changes in national regulations. Taking the above factors into consideration, the auditing and accounting professions all over the world face various challenges, and South Africa (SA) is no exception. Thus, it was imperative for these professions in SA to make the same radical alterations. One of the areas demanding attention was the process of becoming a Chartered Accountant (CA). Inter alia, one focus area was the final examination in the qualifying process. The Chartered Accountant Qualifying Examination Part One (QE Part 1) has been changed from a closed-book assessment to an open-book assessment. This change is relevant because of the importance of the examination itself and the apparent lack of intensive research on students’ perceptions of this type of assessment. In my research I explored the perceptions of taxation students on open-book assessment in the QE Part 1. My study commenced with a focus group (consisting of students that had no previous open-book assessment exposure). I used Interactive qualitative analysis (IQA) as qualitative research method. During this focus group, the students identified ten perceptions (also referred to as affinities) on open-book assessment. For each affinity the focus group provided a descriptive name and an explanatory definition. These affinities were: good preparation, back-up, encourage, general advantages, improve quality of answers, negative symptoms, negative environment, personal experience and hindrance, different approach and time management. This group of students also identified relationships between these different affinities. These relationships were summarized and reflected in a system interrelationship diagram (SID). Findings from this SID indicated that students perceive good preparation as the strongest driver for successful completion of an open-book assessment. The SID indicates three primary outcomes namely negative symptoms, a different approach and time management. The affinities as identified by the focus group were then used during the interviews (conducted with students who had previous open-book assessment exposure). During the IQA interviews, the students were asked to comment on the posed affinities and the possible relationships between them. These findings were summarized and reflected in an interview SID. This SID indicated that these students perceived the primary driver in the system to be a different approach with two primary outcomes - negative environment and improvement in quality of answers. The IQA method is in essence a theory–generating tool that assisted me in my understanding of a group and individual students’ perceptions, before and after exposure to an open-book assessment.
Dissertation (MCom)--University of Pretoria, 2011.
Taxation
unrestricted

Several stakeholders in Nigeria’s oil and gas industry have emphasized the need for petroleum sector reforms in Nigeria. Canada is reputed to have one of the best oil and gas tax regimes in the world. This thesis argues that certain tax measures in Canada’s oil and gas industry have considerable potential for addressing certain industry inefficiencies in Nigeria’s petroleum sector. In developing this argument, this thesis gives an overview of oil and gas taxation in both jurisdictions and examines the possibility of transferring laws between Nigeria and Canada by exploring legal and tax comparative law theories. The thesis also examines the major challenges in Nigeria’s oil and gas industry and identifies viable areas in Canada’s oil and gas tax system which have the potential to address these challenges. Given the peculiarities of oil and gas taxation in each jurisdiction, this thesis suggests that the selected Canadian fiscal and administrative measures may require certain modifications in order to make these measures more suitable for Nigeria’s legal and tax system.

This study discusses South Africa’s tax incentives for small businesses and identifies shortcomings and areas of concern within the tax incentive regimes. A comparison of small business tax incentives provided by Australia, India, and the United Kingdom is made with South Africa’s small business tax incentives to identify similarities and differences, and new lessons are learned from the approaches of other countries. As a result of the comparison with the tax dispensations available to small businesses in other countries, the study recommends additional tax incentives that could be implemented by South Africa. Only those tax incentives that are available in other countries but not in South Africa that were deemed worthwhile were recommended to be introduced in the Republic. Recommendations were also made based on the gaps identified in South Africa’s small business tax incentives.
Taxation
M. Phil. (Accounting Sciences)

Le financement des municipalités québécoises repose en majeure partie sur des revenus autonomes, dont la principale source découle de leur pouvoir de taxer la richesse foncière. Par conséquent, le législateur, voulant assurer la stabilité financière des municipalités, a strictement encadré le processus de confection et de révision des évaluations foncières par plusieurs lois et règlements. Ceci n’a tout de même pas empêché l’augmentation des demandes de contestations à chaque nouveau rôle. Débutant par une demande de révision administrative, à l’aide d’un simple formulaire, le litige entre la municipalité et le contribuable peut se poursuivre devant le Tribunal administratif du Québec et même la Cour du Québec, la Cour supérieure et la Cour d’appel, où la procédure devient de plus en plus exigeante. La transition du processus administratif à judiciaire crée parfois une certaine friction au sein de la jurisprudence, notamment au niveau de la déférence à accorder à l’instance spécialisée, ou encore à l’égard de la souplesse des règles de preuve applicables devant cette dernière. Par une étude positiviste du droit, nous analysons tout d’abord la procédure de confection du rôle foncier, en exposant les acteurs et leurs responsabilités, ainsi que les concepts fondamentaux dans l’établissement de la valeur réelle des immeubles. Ensuite, nous retraçons chacune des étapes de la contestation d’une inscription au rôle, en y recensant les diverses règles de compétence, de preuve et de procédure applicables à chaque instance. À l’aide de nombreux exemples jurisprudentiels, nous tentons de mettre en lumière les différentes interprétations que font les tribunaux de la Loi sur la fiscalité municipale et autres législations connexes.
Funding for Quebec municipalities relies largely on autonomous revenues. Specifically, their power to tax property wealth is the main source of income. Therefore, in order to ensure the financial stability of municipalities, the legislator has strictly regulated the assessment review process with several laws and regulations. This still has not prevented the increase of demands for reviews with each new roll. Starting with an application for an administrative review, which in fact is simply a form, the dispute between the municipality and the taxpayer may continue before the Administrative Tribunal of Quebec and even the Court of Quebec, the Superior Court and the Court of Appeal, where the complexity of the procedure increases. The transition to the judicial from the administrative process sometimes creates friction in the case law, particularly in terms of deference to be accorded to the specialized authority, or with regard to the flexibility of the rules of evidence that apply to the latter. From a positivist study of law, we first analyze the assessment roll making process by exposing the actors and their responsibilities, as well as the fundamental concepts used for determining the actual value of the properties. We then track every stage of the contestation of an entry on the roll by identifying various rules of jurisdiction, evidence and procedure in each instance. With the help of many jurisprudential examples, we attempt to highlight the different interpretations that the courts do of the Act Respecting Municipal Taxation and other related legislation.

Relatório de Estágio do Mestrado em Gestão apresentado à Faculdade de Economia
O estudo retratado no presente relatório de estágio visa compreender e explicitar o procedimento inspetivo levado a cabo pela Autoridade Tributária e Aduaneira (AT), na Direção de Finanças de Coimbra (DFC), relativamente à avaliação indireta não automática da matéria tributável em sede de Imposto sobre o Rendimento das Pessoas Coletivas (IRC). Esta metodologia de avaliação, efetuada a partir de presunções, possui um caráter subsidiário em relação à avaliação direta (regime regra) e tem como objetivo fundamental tributar as empresas, ainda que por via indireta, segundo o princípio constitucional do lucro real, quando não for de todo possível tributá-las pela capacidade contributiva declarada ou corrigida através da aplicação da avaliação direta. A avaliação indireta da matéria tributável é uma ferramenta crucial no combate à evasão fiscal. Em sede de IRC a lei contempla duas formas: a automática (regime simplificado de tributação) e a não automática. Enquanto que a primeira é de caráter optativo (opting in) para os sujeitos passivos que, podendo, por ela optem, sendo a matéria tributável apurada através de coeficientes pré-determinados, a segunda é de último recurso, meramente subsidiária e apenas terá lugar quando se verifiquem determinados pressupostos legais que colocam em causa a veracidade do lucro declarado. O presente estágio centrou-se essencialmente na observação e acompanhamento das tarefas desenvolvidas pela inspeção tributária da DFC, em particular na análise das suas propostas de tributação por avaliação indireta não automática, em sede de IRC, no biénio 2017/2018, de forma a perceber as situações em que as mesmas foram despoletadas, os critérios de quantificação utilizados, bem como o desfecho que tais propostas tiveram em sede de procedimento de revisão. Para o efeito consultei vários relatórios de inspeção, incluindo os 37 pedidos de revisão apresentados neste período pelos sujeitos passivos alvo.Porque em caso de controvérsia os tribunais são o último patamar de apelo, importante seria conhecer a sua posição sobre as propostas de tributação analisadas e que foram objeto de impugnação. Só que neste momento isso mostra-se impossível. Ainda assim, e de modo a perceber o seu desfecho sobre esta temática, efetuei uma síntese das decisões dos Tribunais Centrais Administrativos ocorridas a nível nacional no biénio 2017/2018.Uma conclusão foi possível retirar: o que a avaliação indireta não automática ganha em eficiência à avaliação indireta automática, perde em eficácia.Palavras chave: lucro real; avaliação indireta da matéria tributável; regime simplificado de tributação; pressupostos; impossibilidade de comprovação e quantificação direta e exata da matéria tributável; IRC; procedimento de revisão.
The study presented in this internship report aims at understanding and clarifying the inspection procedure carried out by the Tax and Customs Authority (AT) at the Coimbra’s Finance Directorate (DFC) regarding the non-automatic indirect assessment of the taxable matter in corporate tax (IRC).This evaluation methodology, based on presumptions, has a subsidiary character in relation to the direct evaluation (rule regime) and its main objective is to tax companies, although indirectly, according to the constitutional principle of the real profit, when it is not possible, at all, to tax them for the declared or corrected tax capacity through the application of direct evaluation.The indirect assessment of taxable income is a crucial tool in combating tax evasion. In IRC, the law contemplates two forms: automatic (simplified taxation regime) and non-automatic. While the former is opt-in for taxable persons who, being able to opt for it, the taxable amount being determined through pre-determined coefficients, the latter is a last resort, merely subsidiary, and will only take place when there are certain legal assumptions that call into question the veracity of the declared profit.The present stage focused mainly on the observation and follow-up of the tasks carried out by the DFC's tax inspection, with focus on the analysis of its non-automatic indirect tax assessment proposals in IRC in the biennium 2017/2018, to perceive the situations in which they were triggered, the quantification criteria used, as well as the outcome that such proposals had in the review procedure. For this purpose, I have consulted several inspection reports, including the 37 requests for review submitted in this period by the target taxable persons.Because in the case of controversy the courts are the last level of appeal, it would be important to know your position on the tax proposals analysed and that have been challenged. However, this is impossible now. Nevertheless, and to understand its outcome on this issue, I have summarized the decisions of the Central Administrative Courts that took place at the national level in the 2017/2018 biennium.One conclusion has been drawn: what non-automatic indirect evaluation gains in efficiency to automatic indirect evaluation, loses effectiveness.Keywords: real profit; indirect assessment of the taxable matter; simplified taxation regime; assumption; impossibility of proof and direct and exact quantification of the taxable matter; corporate tax; revision procedure.