Thin capitalisation – the multinational tax avoidance strategy the budget forgot

We have already seen major amendments to Australia’s tax regime to tackle base erosion and profit shifting (BEPS). Several more significant measures were announced in the federal budget, most notably the diverted profits tax, aimed at multinationals which shift tax to a lower taxing jurisdiction. Yet to date, a very simple tax minimisation strategy has been largely ignored in the ongoing reforms and was ignored in the federal budget. Excessive debt loading is a problem that not been afforded the same attention as other aggressive tax planning strategies adopted by multinationals.

What if tax reform was a fundamental human right?

As an election looms in Australia, the tax debate continues unabated. Self-interest abounds. When we remove self-interest, we are often reduced to standard design principles for a taxation system. Lost in this discussion is the fundamental purpose of tax, which is to finance government expenditure. Most would argue that tax revenue should be sufficient to meet basic economic and social needs of the community. But how does a community determine what these basic economic and social needs should be? One way is by using a human rights framework. This can provide guidance for both developing and developed countries considering tax reform.

Fundamental Tax Legislation [24th Edition]

Fundamental Tax Legislation 2016 contains the essential provisions from the primary legislation that affects Australia's taxation system. Updated and expanded for changes which occurred in 2015, this volume is an indispensable reference for undergraduate and postgraduate students of taxation. The Year in Review section has been updated to summarise the main legislative developments in taxation over the previous 12 months, a listing of the passage of tax related legislation during the last year and the inclusion of reference statistics (such as CPI quarterly figures and individual tax rates for residents and foreign residents). Also fully updated and revised to reflect the changes in 2015 is the Tax Rates and Tables section, which contains an accessible summary of the main tax rates and tables that students will need to refer to for their tax studies.

Tax Reform and Payout Policy:Do Shareholder Clienteles or Payout Policy Adjust?

Changes in taxation of corporate dividends offer excellent opportunities to study dividend clientele effects. We explore payout policies and ownership structures around a major tax reform that took place in Finland in 2004. Consistent with dividend clienteles affecting firms’ dividend policy decisions, we find that Finnish firms altered their dividend policies based on the changed tax incentives of their largest shareholders. While firms adjust their payout policies, our results also indicate that ownership structures of Finnish firms also changed around the 2004 reform, consistent with shareholder clienteles adjusting to the new tax system.

Essays on Stock Option Compensation and the Role of Incentives and Risk (summary section only)

Managerial pay-for-performance sensitivity has increased rapidly around the world. Early empirical research showed that pay-for-performance sensitivity resulting from stock ownership and stock options appeared to be quite low during the 1970s and early 1980s in the U.S. However, recent empirical research from the U.S. shows an enormous increase in pay-for-performance sensitivity. The global trend has also reached Finland, where stock options have become a major ingredient of executive compensation. The fact that stock options seem to be an appealing form of remuneration from a theoretical point of view combined with the observation that the use of this compensation form has increased significantly during the recent years, implies that research on the dynamics of stock option compensation is highly relevant for the academic community, as well as for practitioners and regulators. The research questions of the thesis are analyzed in four separate essays. The first essay examines whether stock option compensation practices of Finnish firms are consistent with predictions from principal-agent theory. The second essay explores one of the major puzzles in the compensation literature by studying determinants of stock option contract design. In theory, optimal contract design should vary according to firm characteristics. However, in the U.S., variation in contract design seems to be surprisingly low, a phenomenon generally attributed to tax and accounting considerations. In Finland, however, firms are not subject to stringent contracting restrictions, and the variation in contract design tends, in fact, to be quite substantial. The third essay studies the impact of price- and risk incentives arising from stock option compensation on firm investment. In addition, the essay explores one of the most debated questions in the literature, in particular, the relation between incentives and firm performance. Finally, several strands of literature in both economics and corporate finance hypothesize that economic uncertainty is related to corporate decision-making. Previous research has shown that risk tends to slow down firm investment. In the fourth essay, it is hypothesized that firm risk slows down growth from a more universal perspective. Consistent with this view, it is shown that risk not only tends to slow down firm investment, but also employment growth. Moreover, the essay explores whether the nature of firms’ compensation policies, in particular, whether firms make use of stock option compensation, affects the relation between risk and firm growth. In summary, the four essays contribute to the current understanding of stock options as a form of equity incentives, and how incentives and risk affect corporate decision-making. By this, the thesis promotes the knowledge related to the modern theory of the firm.

Tax havens and their impacts on the non-haven countries

Tax havens have attracted increasing attention from the authorities of non-haven countries. The financial crisis exacerbates the negative attitude to tax havens. Offshore zones are now under strong pressure from the international, both financial and political institutions. Thus, the thesis will focus on the current problem of the modern economy, namely tax havens and their impact on the non-haven countries. This thesis will be based on the several articles, in particular “Tax Competition With Parasitic Tax Havens” by Joel Slemrod and John D. Wilson (University of Michigan, 2009) and “Do Havens Divert Economic Activity” by James R. Hines Jr., C. Fritz Foley and Mihir A. Desai (Ross School of Business, 2005). This paper provides two completely different and contradictory viewpoints on the problem of coexisting tax havens and non-haven countries. There are two models, examined in this work, present two important researches. The first one will be concentrated on the positive effect from tax havens whereas the last model will be focused on the completely negative effect from offshore jurisdictions. The first model gives us a good explanation and proof of its statement why tax havens can positively influence on nearby high-tax countries. It describes that the existence of offshore jurisdictions can stimulate the growth of operations and facilitates economic activity in non-haven countries. In contrast to above mentioned, the model with quite opposite view was presented. This economic model and its analysis confirms the undesirability of the existence of offshore areas. Taking into consideration, that the jurisdictions choose their optimal policy, the elimination of offshores will have positive impact on the rest of countries. The model proofs the statement that full or partial elimination of tax havens raises the equilibrium level of the public good and increases country welfare. According to the following study, it can be concluded that both of the models provide telling arguments to prove their assertions. Thereby both of these points of view have their right to exist. Nevertheless, the ongoing debate concerning this issue still will raise a lot of questions.

Second-best tax policy in a growing economy with externalities

This paper investigates the exploitation of environmental resources in a growing economy within a second-best scal policy framework. Agents derive utility from two types of consumption goods one which relies on an environmental input and one which does not as well as from leisure and from environmental amenity values. Property rights for the environmental resource are potentially incomplete. We connect second best policy to essential components of utility by considering the elasticity of substitution among each of the four utility arguments. The results illustrate potentially important relationships between environmental amentity values and leisure. When amenity values are complementary with leisure, for instance when environmental amenities are used for recreation, taxes on extractive goods generally increase over time. On the other hand, optimal taxes on extractive goods generally decrease over time when leisure and environmental amenity values are substitutes. Unders some parameterizations, complex dynamics leading to nonmonotonic time paths for the state variables can emerge.

Explosive Hyperinflation, Inflation Tax Laffer Curve and Modelling the use of Money

This paper analyzes the existence of an inflation tax Laffer curve (ITLC) in the context of two standard optimizing monetary models: a cash-in-advance model and a money in the utility function model. Agents’ preferences are characterized in the two models by a constant relative risk aversion utility function. Explosive hyperinflation rules out the presence of an ITLC. In the context of a cash-in-advance economy, this paper shows that explosive hyperinflation is feasible and thus an ITLC is ruled out whenever the relative risk aversion parameter is greater than one. In the context of an optimizing model with money in the utility function, this paper firstly shows that an ITLC is ruled out. Moreover, it is shown that explosive hyperinflations are more likely when the transactions role of money is more important. However, hyperinflationary paths are not feasible in this context unless certain restrictions are imposed.

Tax-Based Fisheries Management: The Case Study Of The Cantabrian Anchovy Fishery

A dynamic optimisation framework is adopted to show how tax-based management systems theoretically correct the inefficient allocation of fishing resources derived from the stock externality. Optimal Pigouvian taxes on output (τ) and on inputs (γ) are calculated, compared and considered as potential alternatives to the current regulation of VIII division Cantabrian anchovy fishery. The sensibility analysis of optimal taxes illustrates an asymmetry between (τ) and (γ) when cost price ratio varies. The distributional effects also differ. Special attention will be paid to the real implementation of the tax-based systems in fisheries.

The political econmoy of state government debt : an analysis of constitutional limitations (1961-1990)

Over the past decade, scholarly interest concerning the use of limitations to constrain government spending and taxing has noticeably increased. The call for constitutional restrictions can be credited, in part, to Washington's apparent inability to legislate any significant reductions in government expenditures or in the size of the national debt. At the present time, the federal government is far from instituting any constitutional limitations on spending or borrowing; however, the states have incorporated many controls on revenues and expenditures, the oldest being strictures on full faith and credit borrowing. This dissertations examines the efficacy of these restrictions on borrowing across the states (excluding Alaska) for the period dating from 1961 to 1990 and also studies the limitations on taxing and spending synonymous with the Tax Revolt.

We include socio-economic information in our calculations to control for factors other than the institutional variables that affect state borrowing levels. Our results show that certain constitutional restrictions (in particular, the referendum requirement and the dollar debt limit) are more effective than others. The apparent ineffectiveness of other limitations, such as the flexible debt limit, seem related to the bindingness of the limitations in at least half of the cases. Other variables, such as crime rates, number of schoolage children, and state personal income do affect the levels of full faith and credit debt, but not as strongly as the limitations. While some degree of circumvention can be detected (the amount of full faith and credit debt does inversely affect the levels of nonguaranteed debt), it is so small when compared to the effectiveness of the constitutional restrictions that it is almost negligible. The examination of the tax revolt era limitations yielded quite similar conclusions, with the additional fact that constitutional restrictions appear more binding than statutory ones. Our research demonstrates that constitutional limitations on borrowing can be applied effectively to constrain excessive borrowing, but caution must be used. The efficacy of these restrictions decrease dramatically as the number of loopholes increase.

Which policy option can be more cost-effective in promoting the use of energy efficient appliances in Europe? A comparison of energy taxes, subsidies, tax credits and bans.

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Los Gastos Fiscales en España en los últimos años.

En este trabajo se realiza un análisis de los gastos fiscales en España durante los últimos 10 años. Para ello se parte de la definición y características de estos pasando por sus ventajas e inconvenientes, sus tres métodos de estimación del mismo y el utilizado en España, contextualizándolo en el marco legal básico del que emana los Presupuestos Generales del Estado. Continuamos abordando los gastos fiscales a través de tres puntos de vista diferentes: Presupuestario, donde se analizan los gastos fiscales a través de los Beneficios Fiscales y del Presupuesto de Ingresos. Por Políticas de Gasto, donde estos son analizados a través de las políticas a los que son destinados dichos gastos. Y finalmente, desde el punto de vista Impositivo, donde se analizan a través de cada impuesto individualmente en que elemento del impuesto se recogen dichos Beneficios Fiscales relacionándolos con las políticas de gasto a los que son destinados.