Efficient taxation of multi-national enterprises in the European Union. Bruges European Economic Policy (BEEP) Briefing 5/2003

Current arrangements for multi-national company taxation in EU are plagued by severe conceptual and administrative problems, leading to high compliance costs, considerable uncertainty and ample room for abuse. Integration is amplifying these difficulties. There are two possible approaches in designing an efficient trans-border corporate tax system for the European Union. The first is to consolidate the EU-wide operations of MNEs, using an agreed common base as the reference variable, and then to apportion this total tax base using some presumptive indicators of activity in each tax jurisdiction – hence, implicitly, of the likely benefits stemming from each location. The apportionment formula should respect requisites of neutrality between productive factors and forms of corporate financing. A radically different approach is also available that offers considerable advantages in terms of efficiency, simplicity and decentralisation, including full administrative autonomy of national tax authorities. It entails abandoning corporate income as the relevant tax base and taxing at a moderate rate some agreed measure of business activity such as company value added, sales or employment. These are the variables usually considered in formula apportionment, but they would apply directly without having first to go through the complications of EU-wide consolidation based on a common-base definition. Reference to a broad base, with no exemptions or deductions, would allow to set low statutory rates.

A Microsimulation of the Impact of Tax Reforms on Child Poverty: the Case of Italy. Bruges European Economic Research (BEER) Papers 29/February 2014

Microsimulation models have been used in order to find efficient counteractive instruments to poverty. The objective of this paper is to analyse the impact of fiscal policy on poverty, insisting on child poverty rates. Empirical analysis suggests that in fighting poverty, a mix of policies need to be in place, fiscal reforms increasing tax allowances such as child benefit granted to parents with dependent children, are not sufficient to reduce child poverty.

From Convergence to Diffusion: The EU's influence on national tax systems. ACES Cases No. 2011.2

In this article I investigate to what extent European Integration stimulates policy convergence and diffusion of various forms of tax policy. Using a mixed-methods design, I find that several causal mechanisms contribute to an EU-wide diffusion of tax policies: imposition, competition, harmonization and learning/communication. I show that these mechanisms have different effects on different forms of taxation. Even if the ultimate outcome of this influence only in few cases leads to unconditional convergence, the EU has markedly accelerated policy diffusion among its member states.

Changes in tax structures in European Union Member States

The European Union does not have a comprehensive common tax policy and substantial changes in this specialized policy area are not likely in the foreseeable future. Albeit common rules, requirements, minimum rates for certain tax types were implemented in the last few decades, they barely limit the Member States in using their tax policies as one of the worthiest elements of their arsenal in increasing competitiveness or quite the contrary, to undermining their own international competitiveness inadvertently through a misguided tax policy. In this article, we put the tax policies of the Visegrad Group and the Eurozone core countries (Germany, Austria and the Netherlands), as well as changes in these policies under the magnifying glass, in terms of the impact of tax structure changes on economic growth and employment in the last decade.

Federal tax deductibility for local taxes and its effect on local revenue policies

This dissertation analyzes whether and how changes in federal tax policy affect local tax policies, specifically, the elimination of the federal deductibility of state and local taxes for individual taxpayers by the Tax Reform Act of 1986 (TRA86) in 59 California cities. Two methods are used in the study: a survey of local revenue officials and a time event time-series/cross sectional sales tax reliance study.^ The reliance study uses a covariance model to pool cross-section and time-series observations. The results of the reliance study indicate a statistically significant overall decline in sales tax reliance after 1986. The results of the survey indicate that local policy makers generally do not believe that federal deductibility is an important factor when considering raising local sales taxes. Further analysis shows that local revenue officials claiming federal deductibility is not an important factor are associated mostly with cities that registered no significant decline in sales tax reliance after 1986. Similarly, local revenue officials claiming federal deductibility is an important factor when considering local tax policy are associated mostly with cities that suffered a significant decline in sales tax reliance after 1986.^ Of that group, further analysis shows that the declines in sales tax reliance are associated mostly with cities located in the southwestern part of the state. When compared to other cities in the state, an analysis of variance reveals that there are a series of statistically significant factors associated with southwestern cities which may contribute to the decline in sales tax reliance following the enactment of the Tax Reform Act of 1986. ^

Understanding the Impact of the Property Tax Appeal Process on Assessment Uniformity: Procedures, Structures, and Outcomes

Property taxes serve as a vital revenue source for local governments. The revenues derived from the property tax function as the primary funding source for a variety of critical local public service systems. Property tax appeal systems serve as quasi-administrative-judicial mechanisms intended to assure the public that property tax assessments are correct, fair, and equitable. Despite these important functions, there is a paucity of empirical research related to property tax appeal systems. This study contributes to property tax literature by identifying who participates in the property tax appeal process and examining their motivations for participation. In addition, the study sought to determine whether patterns of use and success in appeal systems affected the distribution of the tax burden. Data were collected by means of a survey distributed to single-family property owners from two Florida counties. In addition, state and county documents were analyzed to determine appeal patterns and examine the impact on assessment uniformity, over a three-year period. The survey data provided contextual evidence that single-family property owners are not as troubled by property taxes as they are by the conduct of local government officials. The analyses of the decision to appeal indicated that more expensive properties and properties excluded from initial uniformity analyses were more likely to be appealed, while properties with homestead exemptions were less likely to be appealed. The value change analyses indicated that appeals are clustered in certain geographical areas; however, these areas do not always experience a greater percentage of the value changes. Interestingly, professional representation did not increase the probability of obtaining a reduction in value. Other relationships between the variables were discovered, but often with weak predictive ability. Findings from the assessment uniformity analyses were also interesting. The results indicated that the appeals mechanisms in both counties improved assessment uniformity. On average, appealed properties exhibited greater horizontal and vertical inequities, as compared to non-appealed properties, prior to the appeals process. After, the appeal process was completed; the indicators of horizontal and vertical equity were largely improved. However, there were some indications of regressivity in the final year of the study.

Equity for taxpayers within Australia’s retirement savings regime : a dissenting opinion

This article asks the question whether Australia’s retirement savings regime, specifically the superannuation component and the attached taxation concessions, is a regime which is equitable to all taxpayers. In a dissenting opinion, it is argued that the current regime, along with the changes proposed by the Federal Government in its response to the Henry Review, does not result in a retirement savings regime which benefits all taxpayers equally. As such, it is suggested that the only way to ensure an equitable regime is to incorporate a gender perspective into public finance analysis to determine how the retirement savings policies affect women and men differently. In doing so, a specific tax policy which provides for additional, fiscally significant concessions for taxpayers who do not fit the criteria of a ‘normal’ taxpayer, that is a taxpayer working as an employee in a full time position for an uninterrupted 35 years, should be incorporated into Australia’s current fiscal policy.

A nation’s role in addressing base erosion and profit shifting : balancing sovereignty with international collaboration and coordination

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. In a world of cross-border investments and business transactions, all tax regimes impact on one another. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether to engage in both collaboration and coordination with other nations and supranational bodies alike or maintain an individualised stance in relation to its tax policy. Whatever the decision, there is arguably an exercise in national sovereignty in some form. In the context of an international tax regime, whether that regime is interpreted broadly as meaning international norms generally adopted by nations around the world or domestic regimes legislating for cross-border transactions, rhetoric around national fiscal sovereignty takes on many different forms. At one end of the spectrum it is relied upon by financial secrecy jurisdictions (tax havens) as a defence to their position on the basis that ‘other’ nations cannot interfere with the fiscal sovereignty of a jurisdiction. At the other end of the spectrum, it is argued that profit shifting and international tax avoidance if not stopped is, in and of itself, a threat to a nation’s fiscal sovereignty on the basis that it threatens the ability to tax and raise the revenue needed. This paper considers a modern conceptualisation of sovereignty along with its role within international tax coordination and collaboration to argue that a move towards a more unified approach to addressing international base erosion and profit shifting may be the ultimate exercise of national fiscal sovereignty. By using the current transfer pricing regime as a case study, this paper posits that it is not merely enough to have international agreement on allocation rules to be applied, but that the ultimate exercise of national sovereignty is political agreement with other states to ensure that it is governments which determine the allocational basis of worldwide profits to be taxed. In doing so, it is demonstrated that the arm’s length pricing requirement of the current transfer pricing regime, rather than providing governments with the ability to determine the location of profits, is providing multinational entities with the ultimate power to determine that location. If left unchecked, this will eventually erode a nation’s ability to capture the required tax revenue and, as a consequence, may be deemed a failure by nation states to exercise their fiscal sovereignty.

A nation's role in addressing base erosion and profit shifting : sovereignty in relation to transfer pricing

The notion of sovereignty is central to any international tax issue. While a nation is free to design its tax laws as it sees fit and raise revenue in accordance with the needs of its citizens, it is not possible to undertake such a task in isolation. Tax interactions between sovereign states cannot be avoided. Ultimately, the interactions mean that a nation must decide whether or engage in both collaboration and co ordination with other nations and supranational bodies alike or maintain a unilateral stance in relation to its tax policy. This article considers a modern conceptualisation of sovereignty to argue that a move towards a more unified approach to addressing international base erosion and profit sharing may be the ultimate exercise of national fiscal sovereignty.

Submission to House of Representatives Standing Committee on Economics Inquiry into Home Ownership

This paper empirically examines the effect of current tax policy on home ownership, specifically looking at how developer contributions impact house prices. Developer contributions are a commonly used mechanism for local governments to pay for new urban infrastructure. This research applies a hedonic house price model to 4,699 new and 25,053 existing house sales in Brisbane from 2005 to 2011. The findings of is research are consistent with international studies that support the proposition that developer contributions are over passed. This study has provided evidence that suggest developer contributions are over passed to both new and existing homes in the order of around 400%. These findings suggest that developer contributions are thus a significant contributor to increasing house prices, reduced housing supply and are thus an inefficient and inequitable tax. By testing this effect on both new and existing homes, this research provides evidence in support of the proposition that not only are developer contributions over passed to new home buyers but also to buyers of existing homes. Thus the price inflationary effect of these developer contributions are being felt by all home buyers across the community, resulting in increased mortgage repayments of close to $1,000 per month in Australia. This is the first study to empirically examine the impact of developer contributions on house prices in Australia. These results are important as they inform governments on the outcomes of current tax policy on home ownership, providing the first evidence of its kind in Australia. This is an important contribution to the tax reform agenda in Australia.

Land leasing, land degradation and agricultural productivity in Finland

This study analysed whether the land tenure insecurity problem has led to a decline in long-term land improvements (liming and phosphorus fertilization) under the Common Agricultural Policy (CAP) and Nordic production conditions in European Union (EU) countries such as Finland. The results suggests that under traditional cash lease contracts, which are encouraged by the existing land leasing regulations and agricultural subsidy programs, the land tenure insecurity problem on leased land reduces land improvements that have a long pay-back period. In particular, soil pH was found to be significantly lower on land cultivated under a lease contract compared to land owned by the farmers themselves. The results also indicate that land improvements could not be reversed by land markets, because land owners would otherwise have carried out land improvements even if not farming by themselves. To reveal the causality between land tenure and land improvements, the dynamic optimisation problem was solved by a stochastic dynamic programming routine with known parameters for one-period returns and transition equations. The model parameters represented Finnish soil quality and production conditions. The decision rules were solved for alternative likelihood scenarios over the continuation of the fixed-term lease contract. The results suggest that as the probability of non-renewal of the lease contract increases, farmers quickly reduce investments in irreversible land improvements and, thereafter, yields gradually decline. The simulations highlighted the observed trends of a decline in land improvements on land parcels that are cultivated under lease contracts. Land tenure has resulted in the neglect of land improvement in Finland. This study aimed to analyze whether these challenges could be resolved by a tax policy that encourages land sales. Using Finnish data, real estate tax and a temporal relaxation on the taxation of capital gains showed some potential for the restructuring of land ownership. Potential sellers who could not be revealed by traditional logit models were identified with the latent class approach. Those landowners with an intention to sell even without a policy change were sensitive to temporal relaxation in the taxation of capital gains. In the long term, productivity and especially productivity growth are necessary conditions for the survival of farms and the food industry in Finland. Technical progress was found to drive the increase in productivity. The scale had only a moderate effect and for the whole study period (1976–2006) the effect was close to zero. Total factor productivity (TFP) increased, depending on the model, by 0.6–1.7% per year. The results demonstrated that the increase in productivity was hindered by the policy changes introduced in 1995. It is also evidenced that the increase in land leasing is connected to these policy changes. Land institutions and land tenure questions are essential in agricultural and rural policies on all levels, from local to international. Land ownership and land titles are commonly tied to fundamental political, economic and social questions. A fair resolution calls for innovative and new solutions both on national and international levels. However, this seems to be a problem when considering the application of EU regulations to member states inheriting divergent landownership structures and farming cultures. The contribution of this study is in describing the consequences of fitting EU agricultural policy to Finnish agricultural land tenure conditions and heritage.

Dependência de trajetória nos incentivos fiscais: fragmentação do empresariado na reforma tributária

Desde a promulgação da Constituição de 1988, todos os governos têm buscado realizar a reforma tributária. Há aparente consenso de que essa reforma precisa ser feita. No entanto, os insucessos nas propostas submetidas ao Congresso Nacional têm sido recorrentes. Essa dissertação busca explicar esse aparente insucesso a partir da análise evolutiva histórica de cinco tipos de incentivo fiscal: 1) regional (Sudam, Sudene e Zona Franca de Manaus); 2) guerra fiscal do ICMS; 3) exportação; 4) tributação simplificada (em especial o Simples); e 5) desenvolvimento econômico. O argumento central da pesquisa é o de que a política tributária desenvolvimentista e extrativa, adotada historicamente pelo Estado brasileiro e pautada pela concessão de incentivos fiscais, envolve interesses difíceis de serem revertidos - com características de dependência de trajetória -, que têm condicionado o comportamento do ator fundamental para o desenlace da reforma tributária - o empresariado -, o qual tem atuado de forma fragmentada e na busca por rendas, em vez de atuar de forma concertada buscando o objetivo coletivo pressuposto em uma reforma tributária. A pesquisa evidenciou ter havido uma dinâmica e relevante evolução do sistema tributário no período recente, vinculada em grande medida ao conjunto de incentivos fiscais que foram objeto de análise, o que afasta a hipótese de eventual paralisia decisória e relativizam as hipóteses de pontos de veto e de impasse entre interesses federativos como variáveis explicativas para o insucesso da reforma tributária.

On the optimality of progressive income redistribution

We compute the optimal non-linear tax policy for a dynastic economy with uninsurable risk, where generations are linked by dynastic wealth accumulation and correlated incomes. Unlike earlier studies, we find that the optimal long-run tax policy is moderately regressive. Regressive taxes lead to higher output and consumption, at the expense of larger after-tax income inequality. Nevertheless, equilibrium effects and the availability of self-insurance via bequests mitigate the impact of regressive taxes on consumption inequality, resulting in improved average welfare overall. We also consider the optimal once-and-for-all change in the tax system, taking into account the transition dynamics. Starting at the U.S. status quo, the optimal tax reform is slightly more progressive than the current system.

Impuesto a la renta en Colombia: Una aproximación desde la teoría de la tributación óptima

La política fiscal es un mecanismo con importantes implicaciones en el bienestar de la población. En particular, el impuesto de renta genera incentivos sobre la oferta laboral de los contribuyentes y esto tiene repercusiones sobre su consumo, ingreso y bienestar. En Colombia, el impuesto de renta a personas naturales tiene poca relevancia al interior de la estructura tributaria; sin embargo, es un impuesto que puede ser reformado para obtener mayor recaudo y progresividad de la política fiscal. Este artículo analiza, desde la perspectiva de la tributación óptima, cuál debe ser la estructura óptima del impuesto a la renta a personas naturales en Colombia. Utilizando simulaciones con datos trasversales de la Encuesta de Calidad de Vida se encuentra que el régimen óptimo de tributación de renta a personas naturales para este ejemplo metodológico está compuesto por tasas marginales decrecientes a lo largo de la distribución del ingreso laboral y que este es altamente sensible ante variaciones en la distribución de habilidades.

Growth and public infrastructure

The paper analyzes a multicountry extension of the Barro model of productive public expenditure. In the presence of positive infrastructural externalities between countries, the provision of infrastructure will be inefficiently low if countries do not coordinate. This provides a role for a supranational body, such as the European Union, to coordinate the policies of the individual governments. It is shown how intervention by a supranational body can raise welfare by internalizing the infrastructural externality. Infrastructural externalities increase the importance of tax policy in the growth process and distribute the benefits of taxation across countries.