Mostrando entradas con la etiqueta corporate tax. Mostrar todas las entradas
Mostrando entradas con la etiqueta corporate tax. Mostrar todas las entradas

martes, 9 de septiembre de 2008

Corporate tax cut in UK has little impact, but low VAT raises reputation


Rate cut has little impact on global ranking
Article published by Vanessa Houlder in Financial Times (www.ft.com) on September 8 2008.

This year’s cut in the corporate tax rate has failed to push the UK decisively up the international rankings, according to a new survey that shows Britain’s efforts to improve its tax competitiveness have been blunted by similar efforts elsewhere.

The UK now has the 20th lowest corporate tax rate of the 27 European Union member states, a slight improvement for businesses on last year’s 21st position, according to the survey by KPMG, professional services firm.

The UK’s struggle to close the gap with smaller European competitors is likely to fuel criticism from businesses and opposition politicians.

KPMG said: “This continued downward pressure on worldwide and European corporate tax rates will add to the pressure on the UK authorities to address the UK’s perceived lack of competitiveness on tax.”

The impact of April’s 2 percentage point cut to 28 per cent was tempered by cuts elsewhere, which pushed average global and European corporate tax rates down by 1 percentage point. The UK’s corporate tax rate remains higher than the global average of 25.9 per cent and the EU average rate of 23.2 per cent.

But the UK is facing tough competition for holding companies from smaller low-tax European rivals, particularly Ireland, Luxembourg, Switzerland and the Netherlands, as demonstrated by recent moves out of the UK announced by Shire, UBM, Henderson, Charter and Regus.

These moves recently sparked an angry exchange between Alistair Darling and George Osborne, shadow chancellor, who called for a cut in the rate to 25 per cent which “would go some way towards undoing the damage the government has done by failing to keep pace with European tax rates”.

Mr Darling rejected Mr Osborne’s criticisms of the competitiveness of the business tax system as “wrong”.

Chris Morgan, head of international corporate tax at KPMG, said the relocation of headquarters was not driven by concern about the tax rate although bringing down tax rates was an important long-term objective. The argument was instead focused on the question of whether foreign profits should be taxed in the UK, he said.

The intensity of international tax competition was underlined by the finding that – for the first time since 1994 – no country in the 106-strong sample had raised rates. Competition has been particularly intense in the EU over the past 10 years, moving average corporate tax rates from the highest to the lowest of any group of countries in the OECD.

The relationship between tax rates and overall competitiveness is complex, with many other factors including political stability, infrastructure, access to new markets and a skilled labour force playing an important role. Sue Bonney, KPMG’s head of tax said: “Undoubtedly, the corporate tax rate is an important factor for businesses but it is far from the only factor.”

Big industrialised countries such as the UK typically have much higher rates than small countries. Countries such as Malta, Luxembourg and Switzerland have far lower effective rates than their headline rates as a result of exemptions and special rulings.

In May, Mr Darling acknowledged the challenge facing the tax regime, saying “Business does have a choice. Business is increasingly mobile. Tax rates have to be globally competitive.”

The UK’s corporate rate cut ensured that it continued to have a lower rate than Germany at 29.5 per cent, preserving the Treasury’s goal of having the lowest rate in the G7.

Low VAT raises reputation

Britain has the fourth lowest rate of value added tax in the EU, according to KPMG which said this relatively low rate underpinned the business-friendly reputation of the indirect tax system .

Britain’s 17.5 per cent VAT rate is well below the average in the EU of 19.49 per cent, in contrast to its position on corporate taxes. KPMG said this was in line with the “generally accepted idea” that indirect taxes compensate for reduced corporate tax yields.

This notion was partly supported by the contrast between the EU’s low corporate tax rates and its high VAT rates. Against a global average indirect tax rate of 15.7 per cent, the EU’s average rate was 19.49 per cent.

The UK’s relatively low rate, together with its stability over recent years, helped secure the UK top position in a KPMG survey of the best countries in the world to deal with from an indirect tax perspective.

The survey found that indirect tax rates have remained relatively stable, in contrast to the declines in corporate tax rates. KPMG said if indirect tax yields were compensating for declining corporate tax yields, this was being achieved by widening the indirect tax base and applying rules more strictly.

sábado, 9 de junio de 2007

IBM under the wire tax break



Big Blue’s Under-the-Wire Tax Break
Posted by Peter Lattman, from http://blogs.wsj.com/


It looks like IBM’s tax lawyers are earning their keep. Just two days after they used a complex corporate tax loophole to save an estimated $1.6 billion, the IRS moved to close the loophole down. Here are stories from the WSJ and NYT.



On May 29, IBM said it had structured a $12.5 billion stock repurchase to take advantage of overseas earnings without making them subject to stiff U.S. corporate tax rates. Because they’re designed to make an end around IRS section 367(B) covering U.S. taxes on repatriated earnings, tax lawyers call these deals “Killer B” transactions.


Two days later, the IRS announced plans to issue regulations making companies pay U.S. taxes when they buy back their stock, even if the shares are purchased by an international subsidiary. It said the planned ban on the practice would take effect that day.


Stewart Lipeles, a tax attorney with Baker & McKenzie, told the WSJ it looked like the IRS rushed out a notice after it caught wind of IBM’s “Killer B.” The IRS won’t say.

sábado, 21 de abril de 2007

Intercompany Loans and Profit Shifting

Intercompany Loans and Profit Shifting – Evidence from Company-Level Data
Thiess Buettner (Ifo Institute for Economic Research and CESifo) and Georg Wamser (Ifo Institute for Economic Research) published this paper on March 2007 at CESifo Working Paper Series No. 1959.

Here is the Abstract:

This paper is concerned with tax-planning strategies of multinational corporations. A theoretical analysis discusses the choice of the capital structure in a setting where intercompany loans can be used to shift profits to low-tax countries. Empirical evidence is provided using micro-level panel data of virtually all German multinationals made available by the Bundesbank. This comprehensive dataset allows us to exploit differences in taxing conditions of almost eighty countries during a period of nine years.

The empirical results confirm a robust impact of tax-rate differences within the multinational group on the use of intercompany loans, supporting the profit-shifting hypothesis. However, the implied tax-revenue effects are rather small, suggesting that costs related to adjusting the capital structure for profit-shifting purposes are substantial.

Available at SSRN: http://ssrn.com/abstract=981120

viernes, 20 de abril de 2007

Which Countries Become Tax Havens?

Which Countries Become Tax Havens?
Dhammika Dharmapala (University of Connecticut) and James R. Hines Jr. (University of Michigan) published this paper for the National Bureau of Economic Research (NBER) in December 2006.

Here is the Abstract:

This paper analyzes the factors influencing whether countries become tax havens. Roughly 15 percent of countries are tax havens; as has been widely observed, these countries tend to be small and affluent. This paper documents another robust empirical regularity: better-governed countries are much more likely than others to become tax havens. Using a variety of empirical approaches, and controlling for other relevant factors, governance quality has a statistically significant and quantitatively large impact on the probability of being a tax haven. For a typical country with a population under one million, the likelihood of a becoming a tax haven rises from 24 percent to 63 percent as governance quality improves from the level of Brazil to that of Portugal.

The effect of governance on tax haven status persists when the origin of a country's legal system is used as an instrument for its quality of its governance. Low tax rates offer much more powerful inducements to foreign investment in well-governed countries than elsewhere, which may explain why poorly governed countries do not generally attempt to become tax havens - and suggests that the range of sensible tax policy options is constrained by the quality of governance.

Available at SSRN: http://ssrn.com/abstract=952721

lunes, 5 de febrero de 2007

Corporate Tax Policy and International Mergers and Acquisitions - Is the Tax Exemption System Superior?


Corporate Tax Policy and International Mergers and Acquisitions - Is the Tax Exemption System Superior?


Johannes Becker (University of Cologne) and Clemens Fuest (University of Cologne and CESifo (Center for Economic Studies and Ifo Institute for Economic Research) published this paper at CESifo Working Paper Series No. 1884

Here is theAbstract:

In this paper we ask whether recent claims that the US government should switch from the tax credit system to the exemption system are justified. We study corporate taxation in a model where international capital flows are either greenfield investment projects or acquisitions of existing firms, and where investment is motivated by either cost reduction or market entry reasons. The paper asks how corporate taxation affects the international allocation of capital under different double taxation regimes. We find that the standard view on international taxation only prevails in the case of cost driven greenfield investment. In all other cases the deduction system is no longer optimal from a national perspective and the foreign tax credit system fails to ensure neutrality. However, the desirability of the tax exemption system has to be qualified. We show that the cross border cash flow tax system dominates the exemption system in terms of optimality properties.

Available at SSRN: http://ssrn.com/abstract=959991

lunes, 14 de agosto de 2006

Reaganomics at 25

Well deserved to view editorial in the Weekend Wall Street Journal, entitled Reaganomics at 25:

Twenty-five years ago this weekend, Ronald Reagan signed the Economic Recovery Tax Act. The bill cut personal income tax rates by 25% across the board, indexed tax brackets for inflation and reduced the corporate income tax rate. The anniversary is worth commemorating as a seminal moment that continues to influence policy for the better in the U.S., and around the globe....

[T]he top marginal personal and corporate tax rates are 35%, compared with 70% and 48% in 1981. In the late 1970s the tax on dividends was 70% and the capital gains rate was 50%; now they're both 15%....

The rest of the world, meanwhile, has followed the Gipper down the tax-cut curve. Daniel Mitchell of the Heritage Foundation finds that the average personal income tax rate in the industrialized world is now 43%, versus 67% in 1980. The average top corporate tax rate has fallen to 29% from 48%. This decline in global tax rates has been the economic counterpart to the fall of the Berlin Wall. Most of Eastern Europe has adopted flat tax rates of 25% or lower, and the Russians now have a flat income tax of 13%. In Old Europe, Ireland's corporate and personal income tax rate cuts have helped generate the swiftest economic growth in the EU.

miércoles, 7 de junio de 2006

LLCs are up, Corporations are down

Are Corporations Going the Way of the Edsel?
Posted by Peter Lattman, from http://blogs.wsj.com/law.

LLC’s are way up and corporations are down, according to the latest data from the International Association of Commercial Administrators, which collects state-by-state filings.
Limited Liability Companies are popular because, like corporations, owners have limited personal liability for the debts and actions of the LLC. Other features of LLCs are more like those in partnerships, providing management flexibility and the benefit of pass-through taxation. Here’s the IRS site on LLCs.

Thanks to Larry Ribstein at Ideoblog, here’s the IACA report, which shows that filings for LLCs are up in almost every state, while filings for corporations are down in most states. Of the 35 states with filing data for the past four years, 32 reported increases in LLC filings and 21 reported decreases in corporation filings.

As Ribstein puts it, “the corporate form is hanging on — it’s what most practitioners know. But it’s looking less and less like the future of business associations.”

lunes, 27 de marzo de 2006

Unified Corporate Income Tax in China

Forbes Magazine published an article entitled "China to Enact Unified Corporate Income Tax Law This Year." Once I read the entire article, I think the unification will take years to realize. For example, "Jiang Enzhu, spokesman for the National People's Congress, .... played down the impact of the planned new ruling."
"Jiang indicated that the new, standardized tax regime would not take effect immediately on enactment. We [China's Parliament] will also adopt some transitional steps and bear in mind the carrying capacity of the foreign-funded enterprises,' he said."

Furthermore, "within the government, opinion is divided on tax unification. While some government bodies call for a fair tax system, others fear this could deter future investment from overseas."

According to Chinalawblog.com, "Forbes' assumption that a "fair" tax system equates to one with equal tax rates between foreign and domestic companies completely ignores the wealth of subsidies given to Chinese domestic companies and not given to foreign companies in China. I, and many others, view the lower foreign tax rate as fair because it helps equalize competition between foreign and domestic companies in China by counteracting the subsidies given to domestic companies.
Interestingly enough, there are murmurs that if and when China's corporate tax rate becomes unified, it will be at a rate between the present rates for foreign and domestic companies. I am hearing it will be at around 20 percent."

'With the further implementation of the policy of reform and opening up, the investment environment in China will be further improved. Therefore to make unified arrangements for corporate income tax for both domestic and foreign funded enterprises will not have a big impact on China's efforts to attract foreign investment.'

viernes, 7 de octubre de 2005

The world (Tax) is Flat

There is an interesting editorial in the Wall Street Journal, The World is Flat:

"Sooner or later it had to happen: The mainstream press is finally discovering the flat-tax movement that has been sweeping Europe. It must be painful to credit an idea associated with the likes of Milton Friedman and Steve Forbes, but reality can't be ignored forever.

The latest news is that the government of Greece is contemplating a 25% flat-rate income tax to take effect in 2006, replacing a multiple-tier tax structure with rates of 40% or more. The Finance Minister insists that such a flat-tax reform is necessary to reduce a spiraling budget deficit, and that any lost revenue will be recouped "via an overall increase in income."

By our count, this brings to 11 the number of nations with a single-rate, postcard tax system. More dominoes are expected to fall in the next few years: Bulgaria, Croatia and Hungary are also preparing to feed their thousands of pages of tax code into the shredder in favor of lower, flatter rates. A flat-tax proposal was debated as part of Poland's recent election campaign. And one of the countries that started it all, Estonia, plans to lower its rate one more time, to 20% from 24%, which was down from the initial flat rate of 26%. Lithuania hopes to go to 24% from 33%.

As shown in the nearby table, most of the world's flat-tax nations today are the former Iron Curtain nations, which for 50 years attempted to create a workers' paradise through command-and-control economic systems. Many of these nations have swung full circle in the opposite, free-enterprise direction. Daniel Mitchell, chief economist at the Heritage Foundation, notes that Greece's decision would make it the first non-former communist European nation to adopt the flat tax. East Europe is exporting its economic system westward after all, but not in the way Nikita Khrushchev ever could have imagined.

In response, even Old Europe has had to consider tax reform, lest its economies become increasingly uncompetitive. Rather than catching the flat-tax wave, France, Germany and Italy have been attempting to stop it by outlawing tax competition through international entities, such as the OECD, the European Union and United Nations.

But in the meantime, Germany has decided it can't wait and has announced plans to cut its corporate tax rate to 19% from 25%. During last month's election campaign, the opposition party's candidate for finance minister, Paul Kirchhof, championed a 25% flat tax "so that workers don't need 12 Saturdays but 10 minutes to complete their taxes." Some analysts blame the proposal for the opposition's late collapse in the polls, as incumbent Gerhard Schröder's party fanned fears about the flat tax. But the fact that it was debated at all shows that even Germans realize they are under competitive tax pressure.

And what of the United States? The postcard flat-tax concept was virtually invented on these shores, originally by Mr. Friedman. Americans devised the economically optimal tax system and much of the world seems ready to embrace it -- just not us.

Back in the 1980s, a few Democrats (Bill Bradley, Dick Gephardt) entertained a tax reform of flatter rates and fewer deductions. But nowadays the political left derides the concept as some sinister plot to let Rolls Royce and yacht owners slash their tax bills. Their ideological blinders prevent them from learning the lesson that the new political class in Russia, Estonia and now Greece accept as a 21st-century economic reality: The best way to get more taxes out of rich people is to generate more rich people, and then give them more incentive to report their income by keeping tax rates low.

Russia, for example, has reported that it now gets more tax revenues from the rich from its 13% flat tax than from its pre-existing Swiss cheese tax code with massive evasion and 50%-plus tax rates. Russia's revenues with the flat tax grew in real terms by 28% in 2001, 21% in 2002, and 31% in 2003, according to a recent analysis by the Hoover Institution. If the U.S. had that kind of revenue growth, our politicians would be wringing their hands over what to do with budget surpluses.

Last year the Internal Revenue code achieved a new Olympic record for complexity, with nine million words -- 12 times the length of the King James Bible. High tax rates and mindless tax complexity are an economic ball and chain. We hope President Bush's tax reform commission will cut through the class-warfare blather later this month and endorse a simple, broad-based, single-rate tax system."

The WSJ published a table showing the flat tax rates in these eleven countries. I have added below the 2004 GDP growth rates in these countries, which usually exceeds the worldwide growth rate of major industrialized countries:

Flat Tax Rates and GDP Growth Rates
Country Flat Tax Rate GDP Growth Rate
Estonia 24% 4.8%
Georgia 12% 5.5%
Greece 25% 4.0%
Hong Kong 16% 2.9%
Latvia 25% 6.8%
Lithuania 33% 7.1%
Romania 16% 4.5%
Russia 13% 7.3%
Serbia 14% 2.0%
Slovakia 19% 3.9%
Ukraine 13% 8.2%
October 8, 2005 in News | Permalink

lunes, 7 de junio de 2004

International Tax Planning in the Age of Ict


Christoph Spengel (Centre for European Economic Research) and Anne Schäfer (Centre for European Economic Research) published the ZEW - Centre for European Economic Research Discussion Paper No. 04-027

entitled "International Tax Planning in the Age of Ict"

Abstract: The increased use of information and communication technologies (ICT) leads to new ways of doing business internationally. Nowadays, firm-specific intangible assets as well as services often constitute the most important factors for the creation of value. Besides, geographic distances tend to be less relevant. The main objective of international tax planning consists of minimising the effective tax rate of the whole company or group. In this paper, it is examined for several instruments of international tax planning whether new chances of minimising the effective tax rate emerge with the use of ICT and to what extent new risks occur.

The analysis comprises the (re)location of a company's residence, the (re)allocation of functions and risks, the implementation of a transfer pricing system, the choice of the form and location of investments abroad as well as hybrid forms of co-operation. For each instrument, both current and non-current tax issues are considered. We conclude that, due to ICT, it is easier to make use of the international tax differential by choosing the optimal location and form of investment and by allocating functions and risks. Thus, companies can pay more attention to the tax-optimal choice between international locations and the importance of this instrument to reduce the effective tax rate is further strengthened by the use of ICT.

Available at SSRN: http://ssrn.com/abstract=552061 or DOI: 10.2139/ssrn.552061