Exempt treatment of financial intermediation services under a value-added tax: an assessment of alternatives

Most countries with a value-added tax (VAT) exempt financial intermediation services from the tax. While exemption is generally perceived to be undesirable, it is also widely regarded as unavoidable because of technical difficulties in applying VAT to these services. This article reviews the standard rationale for exempt treatment and then considers the relative merits of two recent challenges raised in the tax literature. The first challenge involves the application of cash flow taxation to financial intermediation services in a manner that is consistent with an invoice/credit VAT (which is the dominant form). The second challenge proposes a comprehensive system of zero-rating of financial intermediation services, which is supported by a characterization of the household consumption of such services as non-taxable. The author argues that each of these alternatives to an exemption system suffers from both theoretical and practical implementation difficulties that make maintenance of exempt treatment the preferred approach, at least in the short term. There is, however, a simpler alternative to these fundamental reform options, involving modification of just one aspect of an exemption system to relieve some of its more problematic aspects. Many of the interpretative problems and associated inefficiencies that plague an exemption system arise from the need to distinguish between taxable and exempt financial services. The author argues that these difficulties can be eliminated, to a large extent, by basing the distinction on the form of prices. In support of this approach, he points out that it is consistent with the underlying reasons for the application of exempt treatment. The author considers a number of other possible modifications, but these are either rejected outright or viewed with a healthy skepticism. For example, the author is critical of the apparent rationale for the application of cash flow taxation to property and casualty insurers. He also rejects proposals that accept some looseness in the formulaic allocation by financial intermediaries of the costs of business inputs between exempt and taxable services for input credit purposes. In his view, an explicit reliance on pricing structures to draw the boundary between exempt and taxable services is preferable to the provision of relief for blocked input tax credits of financial intermediaries. Finally, the author is skeptical of the case for a policy response intended to address the tax bias under an exemption system for financial intermediaries to insource supplies.

Microfinance best practice : ten parameters of success for development NGOs

Experience has shown that development NGOs typically do not succeed in transforming themselves into financially sustainable providers of financial intermediation services. The reasons for this failure are complex (see Dichter 1999). Nonetheless, the role that NGOs play as microfinance providers is important and the contribution they could make to poverty reduction would be greatly enhanced if they adhered to some simple but essential parameters of success.

Interjurisdictional allocation of multinational banking income : aligning taxation principles with economic activity

This thesis argues that one type of multinational entity – the multinational bank – poses particularly significant challenges to the international tax regime in terms of its current profit allocation rules. Multinational banks are a unique subset of multinational entities, and as a consequence of their unique traits, the traditional international tax regime foes not yield an optimal interjurisdictional allocation of taxing rights. The opportunity for tax minimisation, achievable because of the unique traits, and realised through exploitation of the traditional source and transfer pricing regime, results in a jurisdictional distribution of taxing rights which does not reflect economic reality. There are two distinct ways in which the traditional international tax regime fails to reflect economic activity. The first way that economic activity may not be reflected in the distribution of the taxing rights to income from multinational banking is through the application of traditional source rules. The traditional sources rules allocate income where transactions are completed rather than where the intermediation services are arranged. As a result of their unique commercial role as financial intermediaries, by separating intermediary economic activity from legal transactions with third parties, multinational banks may distort the true location of the activity giving rise to income. The second way in which the traditional tax regime may fail to reflect economic activity is through the traditional transfer pricing regime requiring related or internal transaction to be undertaken at an arm’s length price. The arm’s length pricing requirement is theoretically deficient in its failure to recognise the highly integrated nature of multinational banking. In practice, the arm’s length pricing requirement is also difficult, if not impossible, to apply to multinational banks because of the requirement of comparability. The difficulties associated with the current model have resulted in a subtle move by multinational banks towards global formulary apportionment. This thesis concludes that, for the international taxation of multinational banks, the current source regime should be replaced with a system that allocates profits for tax purposes on the basis of income source, with source determined using a unitary taxation or global formulary apportionment system. It is argued that global formulary apportionment is a theoretically superior model that provides both jurisdiction to tax and allocated profits on the basis of the economic activity that generates the income.

Because it takes a village to fund the answers: Crowdfunding University Research

Whichever way you look at it, online crowdfunding is ramifying. From its foundations supporting creative industry initiatives, crowdfunding has branched into almost every aspect of public and private enterprise. Niche crowdfunding platforms and models are burgeoning across the globe faster than you can trill “kerching”. Early adopters have been quick to discover that in addition to money, they also get free market information and an opportunity to develop a relationship with their market base. Despite these evident benefits, universities have been cautious entrants in the crowdfunding space and more generally in the emerging ‘collaborative economy’ (Owyang, 2013). There are many cultural and institutional legacies that might explain this reluctance. For example, to date universities have achieved social (and economic) distinction through refining a set of exclusionary practices including, but not limited to, versions of gatekeeping, ranking and credentialing. These practices are reproduced in the expected behaviors of individual academics who garner social currency and status as experts, legislators and interpreters (Osborne, 20014: 435). Digitalization and the emergent knowledge and collaboration economies, have the potential to disrupt the academy’s traditional appeals to distinction and to re-engage universities and academics with their public stakeholders. This chapter will examine some of the challenges and benefits arising from public micro-funding of university-based research initiatives during a period of industrial transition in the university sector.Broadly then this chapter asks; what does scholarship mean in a digital ecosystem where sociality (rather than traditional systems for assessing academic merit) affords research opportunity and success? How might university research be rethought in a networked world where personal and professional identities are blurred? What happens when scholars adopt the same pathways as non-scholars for knowledge discovery, development and dissemination through use of emerging practices such as crowdfunding. These issues will be discussed through detailed exploration of a successful pilot project to crowdfund university research; Research My World. This project, a collaboration between Deakin University and the crowdfunding platform pozible.com, set out to secure new sources of funding for the ‘long-tail’ of academic research. More generally, it aimed to improve the digital capacity of the participating researchers and create new opportunities for public engagement for the researchers themselves as well as the university. We will examine how crowdfunding and social media platforms alter academic effort (the dis-intermediation or re-intermediation of research funding, reduction of the compliance burden, opportunities for market validation and so on), as well as the particular workflows of scholarly researchers themselves (improvements in “digital presence-building”, provision of cheap alternative funding, opportunities to crowdsource non-academic knowledge). In addressing these questions, this chapter will explore the influence that crowdfunding campaigns have for transforming contemporary academic practices across a range of disciplinary instances, providing the basis for a new form of engagement-led research. To support our analysis we will provide an overview of the initiative through quantitative analysis of a dataset generated by the first iteration of Research My World projects.