Showing 49 - 60 of 68 publications
March 2016

A Review of Uganda’s Tax Treaties and Recommendations for Action

by Martin Hearson & Jalia Kangave

In June 2014, Uganda announced the temporary cessation of bilateral tax treaty negotiations, and a review of its policy towards such treaties. The main effect of tax treaties is to divide up the ‘rights’ to tax cross-border investment between the state parties, which reduces the possibility that businesses will incur double taxation; in doing so,…

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January 2016

Developing Country Revenue Mobilisation: A Proposal to Modify the ‘Transactional Net Margin’ Transfer Pricing Method

by Michael C. Durst

Developing countries tend to rely more heavily than wealthier countries on corporate tax revenue from multinational companies operating in their jurisdiction. Therefore, the practice that the Organisation for Economic Cooperation and Development (OECD) has labelled ‘base erosion and profit shifting’ (BEPS) – the diversion of taxable income by multinational groups from countries where they conduct…

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November 2015

Measuring Misalignment: the Location of US Multinationals’ Economic Activity Versus the Location of their Profits

by Alex Cobham & Petr Janský

A major international effort – the OECD Base Erosion and Profit Shifting (BEPS) initiative aims to reduce the extent of misalignment between the profits of multinational groups, and the location of their real economic activity. Recent research using balance sheet data has shown major misalignments, with a number of small jurisdictions capturing a tax base…

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October 2015

A Price-Based Royalty Tax?

by Kimberly A. Clausing & Michael C. Durst

This paper considers the merits of a price-based royalty, a royalty for which the rate varies with the product price, as a fiscal instrument for taxing extractive industries. In light of the literature on natural resources taxation, the case for a price-based royalty is appealing. A price-based royalty captures some of the desirable attributes of…

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September 2015

Limitations of the BEPS Reforms: Looking Beyond Corporate Taxation for Revenue Gains

by Michael C. Durst

This paper argues that global corporate tax policies have long been dominated by a political consensus among governments of countries at all levels of economic development, to the effect that forces of tax competition render taxation of the cross-border income of multinational companies both infeasible and unwise. Current tax laws around the world, which permit…

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September 2014

Unitary Taxation in Federal and Regional Integrated Markets

by Erika Dayle Siu with Milly Isingoma Nalukwago,Rachmanto Surahmat,Marcos Aurélio Pereira Valadão

This paper analyses and compares approaches to unitary taxation in federal and regional integrated markets, and explores the potential application of unitary taxation in the context of regional economic communities within Africa, East Asia, and Latin America. The federal models to be examined are the systems of unitary taxation in practice in the United States…

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March 2014

Lessons for International Tax Reform from the US State Experience under Formulary Apportionment

by Kimberly Clausing

This work undertakes a comprehensive analysis of the US state experience under formulary apportionment of corporate income. While formulary apportionment eliminates the possibility of shifting income across states through accounting strategies that manipulate where income is booked, it may heighten the tax responsiveness of formula factors. The present analysis uses the substantial variation in corporate…

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June 2015

Limitations on Interest Deductions: A Suggested Perspective for Developing Countries

by Michael C. Durst

This paper evaluates the efforts of the Organisation for Economic Co-operation and Development (OECD), in its project on base erosion and profit shifting (BEPS), to control profit shifting by members of multinational groups through payments of interest on related-party loans. Currently, members of groups appear be shifting large amounts of income from countries around the…

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Unitary Taxation in the Extractive Industry Sector

by Erika Dayle Siu, Sol Picciotto, Jack Mintz & Akilagpa Sawyerr

This paper analyses whether a global unitary taxation approach to corporate income tax (CIT) can improve the ability of governments to design and administer efficient and effective tax and royalty policies for the extractive industries. Drawing upon experience with unitary approaches to corporate income taxation of the extractive sectors in subnational taxation systems of the…

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April 2015

Unitary Taxation: Tax Base and the Role of Accounting

by Prem Sikka & Richard Murphy

For more than twenty years there have been discussions on the issue of multinational corporations shifting profits from high- to low-tax jurisdictions, with resulting gains to them from the resulting reduction in their effective tax rate. Underpinning much of this debate has been an implicit assumption that, first of all, profits are a fixed and…

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