International business taxation and the business cash flow tax

Abstract

Investments and business profits are internationally mobile. Countries respond by tackling international profit shifting. As a result, the international allocation of taxable profits becomes an increasingly complex and costly issue. Reform proposals either address the Organisation of Economic Co-operation and Development approach to international profit allocation or target tax bases that are less mobile than profits. This paper investigates cash flow as a tax base. A business cash flow tax abolishes current accrual accounting and has the potential to block international profit shifting. Financing vanishes to become a tax-planning tool because the investments’ market return is tax free under a cash flow tax. Profit shifting via intra-group transactions is eliminated if the business cash flow tax is based on the country of destination principle. However, a destination-based business cash flow tax might distort the investment decisions of international groups.