Tax Deal Research Articles

Model Regulations for Collecting State Revenue in Registration of Sale and Purchase Land

Taxes serve as the primary source of income for the nation to finance its diverse requirements. Land sales and purchase taxes are a specialized sort of tax revenue. Nevertheless, the current taxing arrangements for land transactions enforced by the state remain unjust and need more legal certainty. This study evaluates the significance of state taxation regulations in land acquisitions, aiming to establish legal certainty and justice for the community. It proposes that state taxes on land sales should be determined based on the Tax Object Proceeds Value (NJOP). It advocates for implementing a self-assessment system to ensure equitable taxation and legal certainty in Indonesia. This study employs a doctrinal legal research methodology, conceptual approach, and statutory regulations. The sources utilized encompass primary and secondary legal texts, subsequently synthesized through deductive syllogism. The results indicate that the current rules for determining state tax deductions for land sales in Indonesia are invalid and unfair. This is because they need a self-assessment system, which leads to a lack of clarity and transparency. To address this issue, it is necessary to implement the Tax Deal System as the primary method for collecting sales and purchase taxes on land. This system would allow taxpayers to communicate with tax authorities to determine the land's fair value before conducting transactions to ensure that the transaction value and tax amount are based on the actual value of the land.

Taxation of the Digital Economy: An Appraisal of the Effectiveness of the OECD Tax Deal on Low-and-Middle Income Countries

Taxation of the Digital Economy: An Appraisal of the Effectiveness of the OECD Tax Deal on Low-and-Middle Income Countries

Globe: The Potential Costs Of Cooperation

This article argues that the fact that the 2021 global tax deal (focusing on Pillar 2) is cooperative is not in itself proof of the deal being beneficial (and certainly not equally beneficial) for all parties. Developing countries particularly may benefit less and possibly even lose from the agreement. The article focuses on two features of cooperation that may tilt the playing field in favour of developed countries: agenda influence and structural incentives to cooperate. Since the OECD had control over both the agenda and the ways in which the game was structured, it is not surprising that the deal served the interests of its members. Moreover, the mechanism of Pillar 2 encourages participation and discourages future defection. In the current stage of the international tax regime, this is considered a virtue. However, it might also harbour future risks such as lock-in and cartelistic effects that might benefit the leaders of this initiative (the OECD in this case) at the expense of others. Moreover, the current regime grants significant power to those with their hands on the steering wheel. Such power could be used to disadvantage others. In the absence of mechanisms that would curtail the monopolistic power of the former, other countries risk paying excessive prices to belong in this regime. GLoBE, Pillar II, International Tax, Cooperation, OECD, Developing Countries, Agenda Influence, Incentives to cooperate, Lock-in, Cartels

The OECD Global Tax Deal and Developing Countries: Where Do We Stand?

The OECD Global Tax Deal and Developing Countries: Where Do We Stand?

Is the Organisation for Economic Co-operation and Development’s 2021 Tax Deal Fair?

In October 2021, the Inclusive Framework of the Organization for Economic Co-operation and Development (OECD) adopted a new international tax deal, which has been hailed as a major step towards a fair and effective global corporate tax system. In this article, we question this verdict. We analyse this deal on the basis of three complementary fairness principles: preventing free riding by multinational corporations (MNCs), respect for and promotion of the fiscal autonomy of countries, and the limitation of distributive and relational inequalities. We argue that the tax deal is unlikely to lead to a substantial improvement in fairness. We do, however, welcome the deal’s recognition of the need to tax multinational corporations as unitary entities subject to a global minimum effective tax rate. We argue that this recognition creates opportunities for fairer reforms that should be pursued through a more inclusive global decision-making process. <strong>JEL codes:</strong> F230, H260.

Parliament

This overview highlights the Parliament’s (i) Resolution on national vetoes to undermine the global tax deal; (ii) Committee recommendation to tax cryptoassets and use of blockchain to fight tax evasion

The OECD Global Corporate Tax Deal: What It Is, What It Will Do, and Why It’s Good

The OECD Global Corporate Tax Deal: What It Is, What It Will Do, and Why It’s Good

A New Global Tax Deal for the Digital Age

The Organisation for Economic Co-operation and Development (OECD) is in the midst of a project intended to tackle the tax challenges arising from the digitalization of the economy. As initially laid out in its program of work released in May 2019, the goal is to develop consensus on a new taxing right that would allow countries to tax multinationals even in the absence of traditional physical presence. In this paper, the authors argue that upon inspection, the plan seems primarily focused on rebalancing taxing rights mostly among a number of OECD member states plus a few other key non-OECD states, and that, viewed from this perspective, the urgent effort to forge a new global tax deal for the digital age risks deferring a much-needed discussion on the broader distributive implications of the current global tax deal to some unspecified future time. The first part of the paper offers a brief survey of some of the main factors that prompted the OECD to turn its attention to this topic. The second part considers the origins and development of nexus in the international tax regime, showing why this concept is amenable to broad expansion. The third part examines the range of reforms currently under consideration, arguing that the framing on digitalization misses a necessary connection to other pressing international policy programs that are also under development, most notably a global commitment to building institutions that support sustainable economic development. The paper concludes with a prediction that on its current trajectory, the program of work on digitalization is likely to produce a new global tax deal that looks much like the old global tax deal, with a relatively modest redistribution of taxing rights among a few key states, thus missing an opportunity for meaningful reform.

Tax Avoidance through Advance Tax Rulings – Evidence from the LuxLeaks Firms

Our empirical study tests the effect of special tax deals on tax avoidance by multinational corporations. In 2014, the International Consortium of Investigative Journalists published confidential documents identifying hundreds of firms worldwide that had benefited from advance tax rulings. We find that after engaging in an advance tax ruling in the tax haven Luxembourg, firms have lower worldwide effective tax rates than nonruling firms. The results are robust even if we mitigate a potential bias via propensity-score matching. Consequently, this study gives evidence for corporate tax avoidance through special tax deals in the form of advance tax rulings.

A New Global Tax Deal for the Digital Age

The Organisation for Economic Co-operation and Development (OECD) is in the midst of a project intended to tackle the tax challenges arising from the digitalization of the economy. As initially laid out in its program of work released in May 2019, the goal is to develop consensus on a new taxing right that would allow countries to tax multinationals even in the absence of traditional physical presence. In this paper, the authors argue that upon inspection, the plan seems primarily focused on rebalancing taxing rights mostly among a number of OECD member states plus a few other key non-OECD states, and that, viewed from this perspective, the urgent effort to forge a new global tax deal for the digital age risks deferring a much-needed discussion on the broader distributive implications of the current global tax deal to some unspecified future time. The first part of the paper offers a brief survey of some of the main factors that prompted the OECD to turn its attention to this topic. The second part considers the origins and development of nexus in the international tax regime, showing why this concept is amenable to broad expansion. The third part examines the range of reforms currently under consideration, arguing that the framing on digitalization misses a necessary connection to other pressing international policy programs that are also under development, most notably a global commitment to building institutions that support sustainable economic development. The paper concludes with a prediction that on its current trajectory, the program of work on digitalization is likely to produce a new global tax deal that looks much like the old global tax deal, with a relatively modest redistribution of taxing rights among a few key states, thus missing an opportunity for meaningful reform.

The true art of the tax deal: Evidence on aid flows and bilateral double tax agreements

AbstractOf a total of 2,976 double tax agreements (DTAs), some 60% are signed between a developing and a developed economy. AsDTAs shift taxing rights from capital‐importing to capital‐exporting countries, the latter inherently benefit more from the agreements. In this paper, we argue that capital exporters use foreign aid to incite capital importers into signingDTAs. We demonstrate in a theoretical model that in a deal, one country does not trump the other, but that the deal must be mutually beneficial. In the case of an asymmetricDTA, this requires compensation from the capital‐exporting country to the capital‐importing country. ExaminingDTAs that are signed between donor and recipient countries between 1991 and 2012, and using a fixed effects Poisson model, we find that bilateral foreign aid commitments increase by 22% in the year of the signature of aDTA. Evaluated at the sample mean, this translates into around US$ six million additional aid commitments in aDTAsignatory year.

U.S. science groups make last-minute push to influence final tax deal

U.S. science groups make last-minute push to influence final tax deal

The Trouble with Tax Competition: From Practice to Theory

Over the past few years, policymakers have argued that everything from Apple’s Irish tax deal to patent boxes to the LuxLeaks tax rulings represent “harmful tax competition.” Despite the ubiquity of this term, however, there is no internationally accepted definition of so-called harmful tax competition. This Article uses the anti-tax-competition measures proposed and implemented over the last twenty years to reverse-engineer what policymakers believe to constitute harmful tax competition. Their different visions of harmful tax competition lead to three important lessons. First, when governments claim to be limiting tax competition, they are not leveling the playing field so much as they are shifting it in their own favor. Second, international tax competition relies on international tax avoidance, and international tax avoidance relies on international tax competition. Thus, governments are complicit in international tax avoidance, while taxpayers (usually multinational corporations) are complicit in tax competition. Finally, governments often use both anti-tax-competition measures and anti-avoidance measures not just to limit tax competition by other countries but also as an additional form of tax competition that strengthens their own competitive position.

固定资产折旧新政对制造业影响探究

针对国家近年来频频出台固定资产折旧政策，结合企业固定资产价值耗损补偿和更新客观需求，采用判断分析、逻辑推理等方法，简要阐述了固定资产折旧新政内容，从企业税收、经营效率、会计信息、对外投资等角度，系统、深入地分析了固定资产加速折旧新政对我国制造业的影响，以帮助企业掌握国家税收新政推进供给侧改革思想和促进发展新经济思维，抢抓政策机遇争做经济发展先锋。 In view of the state, the policy of fixed assets depreciation has been introduced frequently in re-cent years. The article combines the value consumption of the fixed assets of the enterprise, compensates and updates the objective demand, and adopts the methods of judgment analysis and logical reasoning. This article briefly describes the depreciation of fixed assets, and systematically and deeply analyzed the impact of the new accelerated depreciation of fixed assets on China’s manufacturing industry from the angle of enterprise collection, operation efficiency, accounting information and foreign investment. The purpose is to help enterprises to master the national tax deal to promote ideological supply side reform, to promote the development of the new economical thinking, to seize the opportunity to become a pioneer of economic development.

Taxation of internet gaming and gambling in the European Union

One of the major issues in cross-border internet gambling is taxation of gambling services. The question arises of how to levy VAT and/or betting and gambling taxes on such gambling services in the country of destination. The article addresses this question and examines how VAT will be levied in an EU without borders for services. In addition a brief outline also looks at the way the Dutch betting and gambling tax deals with this phenomenon.

Comment

Comment

Product Variety, Scale Economies, and Environmental Taxes

We discuss how efficiently a unit tax deals with external damage problems when economies of scale characterize a monopolistically competitive market in which consumers' value product variety. It turns out that neither the number of varieties nor the quantity of each variety is at the optimum under a unit tax. Moreover, aggregate production costs are not minimized under a unit tax. For practical policy purposes, some results suggest that a Pigouvian tax can replace a tax taking into account monopoly. Our findings make this conclusion false when the number of firms is endogenous.

Enlisting the Tax Bar

Tax shelters and aggressive planning derive in part from a structural imbalance in our tax system that has not been adequately explored: In important respects, the private tax bar outmatches their counterparts in government. Although a strong policy case can be made for remedying this mismatch, this Article emphasizes two institutional barriers that complicate any solution, rooted in the political economy of taxation and the economics and professional norms of the legal profession. First, although it would be enormously helpful to dramatically increase the staffing levels and pay of government tax administrators, this is a politically daunting task. Second, a fallback strategy is to look to the private bar for help, but they face a significant conflict. Both market pressure and professional norms motivate them to serve their clients, who generally do not have an interest in improving government tax enforcement. In light of these two challenges, what can be done to mitigate the mismatch between the government and private bar? This Article offers two sets of proposals. First, a number of suggestions focus on the government, offering ways to improve recruiting and reinforce the expertise at their disposal without dramatically increasing funding or raising pay substantially across the board. For example, the government should focus on recruiting senior lawyers out of retirement (whose financial demands will be limited) and having them mentor junior lawyers directly from law school (whose private sector pay is high, but not nearly as high as it will become in later years). The government should also consider a loan forgiveness program for these recent graduates, and should also enlist academics to assist with discrete projects. The government should also retain private law firms to litigate tax controversies with extraordinary precedential value. Second, this Article offers guidance about the right way (and the wrong way) to tap the expertise and information possessed by the private bar. It is more effective, whenever possible, to ask lawyers to help the government in a way that also helps their clients. Using this principle, this Article identifies promising opportunities that have been overlooked, and critiques unpromising initiatives that have attracted significant government support. For example, clients do not want their own tax deals shut down, but they feel differently about their competitor's deals, so the government should make more systematic use of this opportunity. Likewise, although clients are less motivated to help the government identify bad transactions that are inadvertently permitted, they are highly motivated to identify good transactions that are inadvertently prohibited. As a result, the government can look to the private bar for help in narrowing overbroad anti-abuse measures. On the other hand, in asking tax advisors to disclose their clients' aggressive transactions - in effect, to rat on their clients - the government is asking for something that clearly is not in the clients' interest. This reality is likely to undercut this initiative, which has been one of the centerpieces of the government's efforts to date.

The Blood before the Stain: An Interview with Joel Rapp

When one thinks of film adaptations of Philip Roth's fiction, Larry Peerce's box office hit Goodbye, Columbus (1969), Robert Benson's stat-studded The Human Stain (2003), or even Ernest Lehman's (tragically) ill-conceived version of Portnoy's Complaint (1972) immediately spring to mind. However, the first Roth story that attracted cinematic attention was not a critically acclaimed or best-selling novel. In fact, the first adaptation of Roth's work is based on a narrative that has never been collected and that most readers have never even heard of: Expect the Vandals, published in the December 1958 issue of Esquire. In most ways, it is an atypical Roth story, an account of two WWII GIs who survive an American landing on a Japanese-held island. The soldiers, Moe Malamud and Ken Moyer, hide out and observe the enemy forces from a distance, that is, until the day Moe witnesses the Japanese committing suicide en masse, an act that leaves both men dumbfounded. The two then have the entire island to themselves, experiencing both the pleasures and the anxieties that isolation brings, until they are rescued on the morning of 30 June 1946 by a group of American soldiers scouting the island. The next day, Ken and Moe stand on the deck of an observer ship while their island hermitage-which readers now realize is near Bikini Atoll-is subjected to an atomic blast. The short story caught the eye of screenwriter-director Joel Rapp, and the rest, albeit little known, is history.Rapp was almost literally born into show business, the son of Philip Rapp (creator of the radio shows The Bickersons and Baby Snooks) and the godson of Fanny Brice and Eddie Cantor. He has written for both the large and small screens, with credits on such popular sitcoms as Gilligan's Island, Bewitched, McHale's Navy, My Favorite Martian, Green Acres, and The Joey Bishop Show. He also has become a horticultural guru, establishing his own indoor plant business in Hollywood, writing several best-selling books on indoor gardening and cooking, appearing for eleven years as Regis Philbin and Kathie Lee Gifford's TV gardener, and making a name for himself as Mr. Mother Earth, Plant Man to the Stars. Prior to this, he traveled with legendary producer Roger Corman to Puerto Rico, where he shot his adaptation of Expect the Vandals. The result was Battle of Blood Island (1960) featuring Rapp as screenwriter and director. Rapp writes about his life in Radio, TV, Mother Earth & Me (BearManor Media, 2004, foreword by Roger Corman). I interviewed him about his experiences in adapting Expect the Vandals, shooting on location, and spending time with Roth discussing his fiction. What follows is the result of an email-based interview in summer 2005.Derek Parker Royal: What was the impetus behind your choice to make Battle of Blood Island?Joel Rapp: Back in 1958 or '59, Roger Corman called and told me that he had a tax deal in Puerto Rico wherein he could make two or three pictures back to back and receive a terrific tax break. He intended to use the same crew to make all three, but with different actors, of course. He asked if I'd be interested in joining him and making one of the flicks. I was thrilled and began searching for a project that would meet the requirements and lo, within a couple of days after his phone call, I stumbled on Expect the Vandals in Esquire, read it, and loved it. Perfect for the requirements-set on an island, two guys mostly located in a cave, great adult dialogue-I figured correctly that it could be made for $35,000 or less. So I contacted Philip Roth's agent, offered him a thousand bucks for the rights, he agreed, and that's the genesis of the movie.DPR: By the time that Expect the Vandals came out, Roth had already had a few stories published. Had you read him before, or was this your first exposure to his fiction?JR: As far as I can recall, this was my first exposure to his fiction, and as I said, I came on the story strictly by accident. …

The Economics Of Location-Based Tax Incentives

Many local governments offer rich tax deals to firms to get these firms to come to their cities. In this brief essay, I review the economics of location-based tax incentives. I first address the positive economics of these incentives and present five theories of why these tax incentives occur. I then consider the normative aspects of these incentives and discuss the conditions under which these theories lead to optimal locations of firms and to optimal bundles of public goods. In general, I argue that tax incentives will generally lead to more efficient locational decisions. There may be undesirable redistributional consequences of these incentives, but these are best handled by national redistribution policy.