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  1. Illicit financial flows and stolen asset recovery
    the Global North must act
    Author: Chowdhary, Abdul Muheet; Diasso, Sebastien Babou
    Published: [2022]
    Publisher:  South Centre, Geneva, Switzerland

    Domestic resource mobilization is essential for developing countries to achieve the Sustainable Development Goals by the deadline of 2030. Concomitantly, Illicit Financial Flows (IFFs), which also lead to asset theft, are major means through which... more

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    Domestic resource mobilization is essential for developing countries to achieve the Sustainable Development Goals by the deadline of 2030. Concomitantly, Illicit Financial Flows (IFFs), which also lead to asset theft, are major means through which these countries are losing resources. This research paper analyzes the World Bank's Stolen Asset Recovery (STAR) database and shows that countries from where assets have been stolen are mostly developing countries, and countries where the stolen assets have been hidden are developed countries. The paper also shows that regarding the pending or ongoing asset recovery cases, there is a clear pattern where the majority of countries waiting to have their assets returned are developing countries, and those who must return them are developed countries. There is an unexplained and unjustified delay by developed countries in the process of returning the frozen assets to developing countries which needs to be addressed as soon as possible. There is also an evaluation of international legal reforms which can be implemented to accelerate the asset recovery process. However, all these will need the full commitment of Global North countries where most of the stolen assets are hidden and which bear the brunt of responsibility for returning them to the developing countries.

     
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  2. Capital income taxation in the Netherlands
    Author: Klemm, Alexander; Hebous, Shafik; Waerzeggers, Christophe
    Published: May 2021
    Publisher:  International Monetary Fund, [Washington, D.C.]

    This paper looks at capital income taxation in the Netherlands from an international and domestic perpective. The Netherlands is a major conduit country for FDI. Recent reforms taken by the Dutch authorities as well as public statements represent a... more

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    This paper looks at capital income taxation in the Netherlands from an international and domestic perpective. The Netherlands is a major conduit country for FDI. Recent reforms taken by the Dutch authorities as well as public statements represent a strong move to address international tax avoidance, but it is too early to be able to detect the impact in the data, and measuring tax avoidance even in the past is fraught with difficulties. Domestically, the unique system, which for many financial assets effectively taxes wealth rather than capital income, leads to inequities and distortions. Owner-occupied housing is strongly tax-favored and in many cases effectively subsidized. Various reforms, not necessarily of a fundamental nature, would improve efficiency and equity

     
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    Source: Staatsbibliothek zu Berlin
    Language: English
    Media type: Ebook
    Format: Online
    ISBN: 9781513573441
    Other identifier:
    Series: IMF working paper ; WP/21, 145
    Subjects: Netherlands; International Tax; Schedular Tax; Debt Bias; Foreign Exchange; Informal Economy; International Tax, Schedular Tax, Debt Bias; Underground Econom
    Scope: 1 Online-Ressource (circa 41 Seiten), Illustrationen
  3. Two Pillar solution for taxing the digitalized economy
    policy implications and guidance for the Global South
    Author: Ovonji-Odida, Irene; Grondona, Veronica; Chowdhary, Abdul Muheet
    Published: [2022]
    Publisher:  South Centre, Geneva, Switzerland

    The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market... more

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    The taxation of the digitalized economy is the single most important topic in international tax negotiations today. The OECD has devised a "Two Pillar solution" to the problem. Pillar One is focusing on a reallocation of taxing rights to market jurisdictions, which are largely expected to be developing countries, and Pillar Two is instituting a global minimum tax. The Pillar One solution, known as Amount A, will be codified into a Multilateral Convention (MLC) and is expected to be placed before countries for signature in early 2023. The solution ushers in a new paradigm in the taxation of multinational enterprises but has immense complexity and likely minimal revenue gains for most developing countries. It will also require them to give up the right of unilateral tax measures on all out-of-scope companies, meaning they will only be able to tax the fewer than 100 companies likely to be in-scope, if at all. The decision to sign or not is thus a historic one, as it will lock developing countries into a constricted new framework, at a time when revenue needs are especially critical to recover the economies from COVID-19 in the context of a turbulent state of the global economy. However, the United Nations too has a solution, known as Article 12B. This operates in a different manner and is a minor modification to the existing decentralized international tax system which is based on bilateral tax treaties, and which developing countries are more familiar with. It is also likely to generate far higher revenues than Amount A, and does not restrict any of their sovereign taxing rights. This Research Paper assesses the various implications for developing countries from adopting the OECD's or the United Nations's respective solutions and concludes with a possible global South response to the Two Pillar solution.

     
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  4. A tough call?
    comparing tax revenues to be raised by developing countries from the Amount A and the UN Model Treaty Article 12B regimes
    Author: Starkov, Vladimir; Jin, Alexis
    Published: [2022]
    Publisher:  South Centre, Geneva, Switzerland

    In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to... more

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    In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve review of any information that taxpayers provide to tax authorities. Our research demonstrates that the comparative revenue effects of the Amount A and Article 12B taxation regimes largely depend on (a) design details of the Article 12B regime, (b) whether the country hosts headquarters of MNEs that may be in scope of Amount A or Article 12B taxation, and (c) what relief from double taxation, if any, the country will grant to domestic taxpayers subject to taxation under either the Amount A or Article 12B regimes.

     
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  5. Pillar 2's Impact on Tax Competition
    Author: Devereux, Michael P.; Vella, John; Wardell-Burrus, Heydon
    Published: 26 August 2022
    Publisher:  [University of Oxford, Sai͏̈d Business School, Centre for Business Taxation], [Oxford]

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    Source: Union catalogues
    Language: English
    Media type: Book
    Format: Online
    Series: Working paper / University of Oxford, Sai͏̈d Business School, Centre for Business Taxation ; 2022, 11
    Subjects: Pillar 2; Inclusive Framework; Minimum Tax; International Tax; Tax Competition; OECD; Tax Reform; Incentives; GloBE; Corporation Tax
    Scope: 1 Online-Ressource (circa 58 Seiten), Illustrationen
  6. Residual profit allocation by income
    a paper of the Oxford International Tax Group chaired by Michael P. Devereux
    Author: Devereux, Michael P.; Auerbach, Alan J.; Oosterhuis, Paul; Schön, Wolfgang; Vella, John
    Published: March 2019
    Publisher:  [University of Oxford, Sai͏̈d Business School, Centre for Business Taxation], [Oxford]

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    Source: Union catalogues
    Language: English
    Media type: Book
    Format: Online
    Series: Working paper / University of Oxford, Sai͏̈d Business School, Centre for Business Taxation ; 2019, 01
    Subjects: International Tax; Tax Reform; Transfer Pricing; Digitalisation; OECD; Transfer Pricing; Intangibles; Tax Avoidance; Tax Competition; Tax Havens; Profit Shifting
    Scope: 1 Online-Ressource (circa 106 Seiten)
  7. ¿Una elección difícil?
    comparación de los ingresos fiscales que recaudarán los países en vías de desarrollo a partir de los regímenes del Monto A y del Artículo 12B de la Convención Modelo de las Naciones Unidas
    Author: Starkov, Vladimir; Jin, Alexis
    Published: [2022]
    Publisher:  South Centre, Ginebra, Suiza

    In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to... more

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    In this research paper, we attempt to estimate the tax revenues to be gained (or lost) by the South Centre and African Union's Member States under the Amount A and Article 12B regimes. Our analysis relied on sources of information available to private sector researchers but did not involve review of any information that taxpayers provide to tax authorities. Our research demonstrates that the comparative revenue effects of the Amount A and Article 12B taxation regimes largely depend on (a) design details of the Article 12B regime, (b) whether the country hosts headquarters of MNEs that may be in scope of Amount A or Article 12B taxation, and (c) what relief from double taxation, if any, the country will grant to domestic taxpayers subject to taxation under either the Amount A or Article 12B regimes.

     
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  8. Impact of a minimum tax rate under the Pillar Two solution on small island developing states
    Author: Sharma, Kuldeep
    Published: [2022]
    Publisher:  South Centre, Geneva, Switzerland

    The Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a... more

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    The Research Paper commences with an overview of Pillar One and Pillar Two followed by detailed discussions on salient provisions of Pillar Two. Pillar Two is envisaged to have a widespread impact on Small Island Developing States (SIDS) which are a distinct group of 38 United Nations (UN) Member States and 20 Non-UN Members/Associate Members of UN regional commissions that are exposed to unique social, economic and environmental vulnerabilities. In all, 36 SIDS that are members of the Group of Seventy-Seven (G-77) have been analysed, namely, Antigua and Barbuda, Bahamas, Bahrain, Barbados, Belize, Cabo Verde, Comoros, Cuba, Dominica, Dominican Republic, Fiji, Grenada, Guinea-Bissau, Guyana, Haiti, Jamaica, Kiribati, Maldives, Marshall Islands, Mauritius, Federated States of Micronesia, Nauru, Papua New Guinea, Samoa, São Tomé and Príncipe, Seychelles, Singapore, Solomon Islands, St. Kitts and Nevis, St. Lucia, St. Vincent and the Grenadines, Suriname, Timor-Leste, Tonga, Trinidad and Tobago, and Vanuatu.

     
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  9. Evaluating the impact of Pillars One and Two
    Author: Tandon, Suranjali; Rao, Chetan
    Published: [2022]
    Publisher:  South Centre, Geneva, Switzerland

    The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare... more

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    The proposed OECD Pillar One and Two reforms mark a significant shift in the way large multinational enterprises are taxed on their global incomes. However, while considering the reform at the proposed scale tax administrators must be able to compare the revenue gains with alternatives. This paper uses open-source data to provide tentative estimates of the impact of Pillars One and Two. The methodology has been detailed so that administrators can replicate it for comparison. Further, the paper provides an assessment from the perspective of developing countries of some of the key design elements of the proposals so as to understand whether they are administrable and to foresee possible challenges.

     
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  10. Capital income taxation in the Netherlands
    Author: Klemm, Alexander; Hebous, Shafik; Waerzeggers, Christophe
    Published: May 2021
    Publisher:  International Monetary Fund, [Washington, D.C.]

    This paper looks at capital income taxation in the Netherlands from an international and domestic perpective. The Netherlands is a major conduit country for FDI. Recent reforms taken by the Dutch authorities as well as public statements represent a... more

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    This paper looks at capital income taxation in the Netherlands from an international and domestic perpective. The Netherlands is a major conduit country for FDI. Recent reforms taken by the Dutch authorities as well as public statements represent a strong move to address international tax avoidance, but it is too early to be able to detect the impact in the data, and measuring tax avoidance even in the past is fraught with difficulties. Domestically, the unique system, which for many financial assets effectively taxes wealth rather than capital income, leads to inequities and distortions. Owner-occupied housing is strongly tax-favored and in many cases effectively subsidized. Various reforms, not necessarily of a fundamental nature, would improve efficiency and equity

     
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    Source: Staatsbibliothek zu Berlin
    Language: English
    Media type: Ebook
    Format: Online
    ISBN: 9781513573441
    Other identifier:
    Series: IMF working paper ; WP/21, 145
    Subjects: Netherlands; International Tax; Schedular Tax; Debt Bias; Foreign Exchange; Informal Economy; International Tax, Schedular Tax, Debt Bias; Underground Econom
    Scope: 1 Online-Ressource (circa 41 Seiten), Illustrationen