Simplicity in taxation has considerable potential advantages. However, attempts to simplify tax systems are only likely to be successful and enduring if they take account of the reasons why taxation is complex. There are strong pressures on tax systems to accommodate a range of important factors, as well as complex and changing national and international environments within which modern tax systems have to operate. This book explores the experiences of simplification in a range of countries and jurisdictions. The authors analyse a range of manifestations of simplification, including tax systems, tax law, taxpayer communications and tax administration. They also review the longer term or more fundamental approaches to simplification, suggesting that in order to strike the optimum balance between simplicity and the aims of a tax system in terms of efficiency and equity, a range of complex environmental factors must all be taken into account. With chapters reflecting on experiences from Australia, China, Canada, Malaysia, New Zealand, Russia, South Africa, Thailand, Turkey, the UK and the US, the authors illustrate differences between jurisdictions and the changing environment in which they operate. This book addresses the crucial balance between simplicity and the other objectives of tax design and reform, and suggests that reformers of the tax system should include simplicity as one of the key evaluators of any design or reform proposal.

Where there's trade, there's taxation. And more often than not these days, that means United States taxation. This book clearly explains basic structural features and accounting issues, corporate and partnership taxation, and the rules governing international transactions, both inbound and outbound. It provides concise answers to such questions as: what is the US tax treatment of mergers and acqusitions?; how are joint ventures and other hybrid entities taxed in the United States?; how does the US foreign tax credit work?; what are the most tax-beneficial ways to form a business in the United States?; and how can special profit and loss allocations under US partnership law be used in international transactions? It helps to provide a clear "picture" of the US tax system, yet the book is also of great value as a quick reference when a US tax problem needs to be solved.

Taxation in Latin America is largely viewed as a means of generating income to keep the government in business. In recent years, progress has been made towards increasing total revenue, but most countries in the region still lag well behind other countries with similar levels of development. More importantly, Latin American policymakers still largely ignore the potential of taxation to contribute to other important development goals. Yet dependence on consumption taxes such as the VAT and the regressive bent of the personal income tax structure have squandered the opportunity to attack the region's serious income inequality. In addition, the importance of efficiency in taxation has also been underestimated with a proliferation of inefficient ad hoc taxes such as those on bank transactions and exports. Governments have repeatedly missed the chance to influence consumption and production patterns by using taxes to effect relative price changes. More than Revenue aims to provide an up-to-date overview of the current state of taxation in the Latin America and Caribbean (LAC) region, its main reform needs, and possible reform strategies that take into account the likely economic, institutional, and political constraints on the reform process.

Nothing impacts more on citizens than taxes, and nothing has had more impact on the way taxes are administered than the information technology revolution. This volume analyzes the experiences of a dozen or more countries in their effort to use information technology to improve taxpayer service, compliance and revenue performance. Administrative re-engineering using information technology is the order of the day. Information technology is changing the boundaries of tax administration from isolated single tax administrative units, to unified tax authorities that administer all taxes including the functions of customs. Information sharing by the many areas of tax administration is the key to reducing compliance costs borne by taxpayers, as well as enhancing the levels of voluntary compliance with tax laws. Private sector service providers are becoming an integrated part of the administration of taxes. The tax administration system of the future is likely to operate much more like the service oriented financial services sector of the present, than the heavy handed, and too often corrupt, bureaucractic institutions of the past. This volume provides some insight into what is being done now, including a sobering discussion of the implementation problems being faced, in order to bring the possibilities of the information technology revolution into the reality of tax administration.

This liber amicorum honours Professor Leif Muten on the occasion of his 70th birthday. The representation in this volume of 27 well-known authors from all over the world is testimony to the important role of Leif Muten in the international tax community. His scholarly interests are well represented among the contributions, which cover a wide range of issues in law and economics. Key issues examined include international tax problems such as the permanent establishment concept in electronic commerce, multilateral tax treaties, international tax avoidance and limitation of treaty benefits. Certain contributions focus specifically on EC tax matters, such as the implications for income taxation of restrictions on free movement and the principle of non-discrimination, and the problem of tax harmonisation in the context of monetary union. The discussion of basic income tax issues ranges from equity in taxation to corporate income tax issues, while economists on the panel explore ideas such as definitions of tax and charge, the utopia of neutral taxation, and the relationship between income taxation and inflation. In addition, as an appropriate reflection of the many years Professor Muten has served the International Monetary Fund, there are articles on comparative tax law issues and on countries in transition. The scope of the collected essays and the calibre of the contributors make the book a fitting tribute to the work of Professor Muten, and render the book of great interest to anyone interested in theoretical and practical tax problems.

This theoretically rooted and research-based book provides insights on the JESSICA funding model which - unlike the traditional non-repayable aid - focuses on supporting sustainable urban development projects in a repayable and recyclable way. Looking through the lens of the JESSICA financial engineering mechanism used in urban transformation, it examines the functioning and performance thereof and formulates policy recommendations for the future. The aim of this volume is to contribute to a deeper understanding of the JESSICA sustainable funding model by exploring its repayable assistance mechanism to support sustainable urban development projects. The authors make several noteworthy contributions to the literature on EU cohesion policy and shed light on the use of the repayable instruments within public interventions, while providing, for the first time, a critical analysis of the JESSICA sustainable funding model from the holistic perspective which is especially relevant for supporting sustainable urban development. Financial Engineering in Sustainable Funding of Urban Development in the EU provides policy-significant findings that are important for EU cohesion policy in the field of repayable assistance to be reinvested in the long term in urban and regional transformation.

No government can be sustained without the ability to tax its citizens. Democratic societies typically guarantee, in varying forms and degrees, a basic set of taxpayer rights. These rights are essential in establishing an effective and reasonable taxation process.Author Duncan Bentley's work argues that it is timely and beneficial to articulate a Model of taxpayers' rights as a guide to best practice in tax administration. It first finds a rationale for a Model in legal and rights theory and concludes that a Model is necessary, timely and a realistic option in the context of current developments in tax administration. Next, it articulates the principles that should underlie any Model. These are drawn from traditional analysis of tax systems and refined to provide a standard approach and interpretation. It is noted that the content of any Model will be determined in part by the approach taken to its interpretation.A classification of taxpayers' rights in the context of the type of enforcement underlying the rights provides the basis for a detailed analysis of enforcement mechanisms. The analysis is conducted in the light of recent developments in the application of constitutional law and alternative dispute resolution theory. The lion's share of this work comprises a detailed analysis and articulation of the primary and secondary legal and administrative rights that should be available to taxpayers in conjunction with a comprehensive framework of principles of good governance and good practice. A wide-ranging comparative analysis and synthesis of the substantial available literature in both law and other disciplines provides support for the articulation of a Model of taxpayers' rights. The Model is appropriate for use as a guide to best practice in tax administration.Professor Bentley's book effectively tackles a host of important issues such as: the theory and framework of taxpayers' rights to provide support and reassurance for particular approaches to tax administration design; the updated principles for analysis of any tax system; the classification of taxpayers' rights so that they can understand why much tax administration and procedure operates in the way it does; the design of legislative mechanisms to assist in the design and drafting of tax administration; and the design and implementation of dispute resolution systems in tax administration. It also tackles issue such as: specific detail on the powers and duties of tax administrators and how they should be exercised; the design and implementation of taxpayers' charters and other guidelines on taxpayers' rights; specific detail on the rules and procedures in tax administration, relating in any way to taxpayers' rights, and how they should be applied; and, clear and articulated standard of best practice in tax administration and governance for quality assurance purposes.In sum, this work will address a number of important issues faced by international tax professionals - including government officials, academics, and practitioners - in a way that's both instructive and constructive.

Why do people evade paying taxes? This is the central question addressed in this volume by Robert McGee and a multidisciplinary group of contributors from around the world. Applying insights from economics, public finance, political science, law, philosophy, theology and sociology, the authors consider the complex motivations for not paying taxes and the conditions under which this behavior might be rationalized. Applying theoretical approaches as well as empirical research, The Ethics of Tax Evasion considers three general arguments for tax evasion: (1) in cases where the government is corrupt or engaged in human rights abuses; (2) where citizens claim inability to pay, unfairness in the tax system, paying for things that do not benefit the taxpayer, excessively high tax rates, or where taxes are used to support an unpopular war; and (3) through philosophical, moral, or religious opposition. The authors further explore these issues by asking whether attitudes toward tax evasion differ by country or other demographic variables such as gender, age, ethnicity, income level, marital status, education or religion. The result is a multi-faceted analysis of tax evasion in cultural and institutional context, and, more generally, a study in ethical dilemmas and rational decision making.

This volume provides a comprehensive analysis of why taxpayers behave the way they do. It reveals the motivations for why some taxpayers comply with the law while others choose not to comply. Given the current global financial climate there is a need for governments worldwide to increase their revenue collections via improving taxpayer compliance. Research into what shapes and influences taxpayer behavior is critical in that any marginal improvement in understanding and dealing with this behavior can potentially have a dramatic impact upon government revenue. Based on Australian data derived from the data bases of the Australian Taxation Office as an example, this book presents findings that provide lessons for tax systems around the world. Regardless of the type of tax system in place, taxpayers of all nationalities are concerned about how their tax authorities deal with non-compliance and in particular how the tax authorities go about encouraging compliance and ensuring a fair tax system for all. The book presents empirical evidence concerning taxpayer compliance behavior with particular attention being drawn to the moral values of taxpayers, the perceived fairness of the tax system and the deterrent measures undertaken by revenue authorities which influence that behavior. Other issues examined include the degree to which tax penalties operate as an effective deterrent to curbing behavior and how taxpayers' level of general tax knowledge and awareness also impacts upon their actions.

The corporate-tax policy of the European Commission has proved one of the major failures in the history of the European Community. Despite efforts by the Commission throughout the 30 years of its existence, and pressure from the business community, little progress has been made in harmonizing corporate taxation in the EU; the Commission's proposals have almost always been turned down at the Council level. Yet harmonization is a crucial step in establishing a common market in Europe. This examination of the efforts of the European Commission to achieve harmonization bases its analysis on the study of theoretical economic models of corporate-tax systems which meet the requirements of a common market and avoid economic inefficiencies, and on an examination of the US federal tax system. Through the examination of theoretical models as well as practical examples, the author studies why repeated attempts at harmonization have failed and concludes that they must take into account not only economic aspects, but also political and legal factors. Harmonization of corporate taxation is not only a legislative exercise; other institutions, such as the EC Court, have an important role to play in the harmonization process, as the US federal experience suggests. The book concludes with a model for corporate-tax harmonization which takes into account both economic theory and the realities of the political and legal process.

This book deals with foundation law in various European countries. It sums up contributions from the most outstanding experts in foundation law in fourteen countries. These are either civil law or common law, and their socio-economical situation is considerably different.
Despite the outstanding differences in each country, foundations have been growing in number and importance all over Europe in the last decades. Political, economical and social changes occurred in various European countries increased foundations' role. The need to focus on foundations' laws and regulations arose in many States for different reasons.
The contributions in this book focus in particular on the recent development of foundation law, on the evolution foundations have undergone in recent years and on trends in law.

The People s Republic of China s tax policies and international obligations are as multifaceted and dynamic as they are complex, developing closely with the nation s rise to the world s fastest-growing major economy. Today, after decades of reform and the entry into the World Trade Organization, China has developed regulatory systems that enable it to provide stable administration, including a tax structure. China s main tax reform can be attributed to the enactment of the Enterprise Income Tax Law, which came into effect on January 1, 2008. Chinese tax regulations include direct taxes, indirect taxes, other taxes, and custom duties and from a collection point of view, China s tax administration adopts a very devolved system, with revenue collected and shared between different levels of government in accordance with contracts between the different levels of the tax administration system. With respect to international treaties, China has established a network of bilateral tax treaties and regional free trade agreements. This publication describes in detail China s complex tax system and policies, as well as major bilateral treaties in which China has entered into using country-by-country analysis.

Lorenzo Riccardi is Tax Advisor and Certified Public Accountant specialized in international taxation. He is based in Shanghai, where he focuses on business and tax law, assisting foreign investments in East Asia. He is an auditor and an advisor for several corporate groups and he is partner and Head of Tax of the consulting firm GWA, specializing in emerging markets.

This book provides English-speakers with a comprehensive description and incisive critique of the Japanese tax system. The third edition explores the Japanese government's latest round of tax reforms - a reaction to the country's prolonged period of recession following the collapse of the 'bubble' phenomenon in 1991. Two brand new chapters discuss the effect of environmental taxes and land tax reform, and much of the original data and empirical material has been updated.

This book is a compilation of contributions exploring the impact of the European Treaty provisions regarding state aid on Member States' legislation and administrative practice in the area of business taxation. Starting from a detailed analysis of the European Courts' jurisprudence on Art.107 TFEU the authors lay out fundamental issues - e.g. on legal concepts like "advantage", "selectivity" and "discrimination" - and explore current problems - in particular policy and practice regarding "harmful" tax competition within the European Union. This includes the Member States' Code of Conduct on business taxation, the limits to anti-avoidance legislation and the options for legislation on patent boxes. The European Commission's recent findings on preferential "rulings" are discussed as well as the general relationship between international tax law, transfer pricing standards and the European prohibition on selective fiscal aids.

The Death of the Income Tax explains how the current income tax is needlessly complex, contains perverse incentives against saving and investment, fails to use modern technology to ease compliance and collection burdens, and is subject to micromanaging and mismanaging by Congress. Daniel Goldberg proposes that the solution to the problems of the current income tax is completely replacing it with a progressive consumption tax collected electronically at the point of sale.

Within an environment made difficult by the continuing economic crisis, the Italian model for crisis management and resolution has helped to avoid many difficulties faced by intermediaries across the globe. However, the Italian model for crisis management will be forced to adapt to the new EU Bank Recovery and Resolution Directive, which introduces a unified regime for such events in all EU countries. This book explores the various methods for crisis management employed in Italian finance. The authors discuss procedures used in the banking and insurance sectors, such as deposit guarantee schemes and alternative dispute resolution systems. They also explore the evolution of the administrative sanctioning systems, and the roles of tax rules and credit rating agencies in Italian finance. This book analyses the evolution of the various crisis management processes, and discusses potential goals and improvements within the context of recent measures suggested by the European Commission.

This book integrates corporate governance, corporate finance and accounting to formulate sound financial management strategies. It offers practical steps for managers using an integrated optimisation financial model to achieve good corporate governance practices which lead to lower risks and higher firm value.

A qualified expert provides leaders in government and business a much-needed primer for accomplishing their most vital task: transforming a purpose into policy through the appropriate acquisition and use of power. At a time when corporations are reeling from mismanagement, a large proportion of homeowners are being forced to default on mortgages and the federal government is rapidly extending its formidable reach into the private sector, it is understandable that many Americans no longer trust big business and government institutions. To get the United States back on track and to preclude the same kinds of disasters in the future, it is imperative for corporate and government leaders as well as private citizens to understand the commonality in all of these events-the use and abuse of power. This text examines these critical events within a framework of power to explain what motivated our leaders in business and government to make the policies that resulted in these outcomes, providing valuable insights on the nature and use of power. It then draws lessons today's leaders can use to improve their use of power. Examples from current affairs and modern business are discussed in a lively, compelling way. Cites examples and case studies from current affairs, modern business, and recent history Explains how and why some corporate leaders abused their power and erased the wealth of their companies and the savings of private individuals Provides tables, charts, and other figures for supporting documentation

This book demonstrates how the reliable measurement of growth in tax revenues, both for a tax system and for its component taxes, is important for the design of tax policy. The need for discretionary changes in tax parameters (such as tax rates, income thresholds and allowances) is conditional on the expected automatic revenue growth generated by the tax system. The properties that generate these automatic revenue changes are referred to as the built-in flexibility, or revenue responsiveness, of the tax. This concept is the central focus of the analyses in this book, which provides an invaluable review and synthesis of analytical results and demonstrates how this concept can be applied in practice to yield estimates of revenue responsiveness in various countries. John Creedy and Norman Gemmell highlight how an understanding of the principal determinants of a tax system's responsiveness, and a knowledge of the relevant magnitudes, are important for the design and reform of tax policy where both revenue and redistributional considerations are typically central to the policy agenda.Providing extensions of analysis to cover indirect taxes, and direct and indirect taxes combined, as well as empirical applications for several countries, Modelling Tax Revenue Growth will be warmly welcomed by researchers and graduate students interested in public finance and government officials and those in international organisations interested in tax revenue growth.

The tax system profoundly affects countless aspects of private behavior. It is a powerful policy influence on the distribution of income and it is the one aspect of government that almost every citizen cannot avoid. With tax reform high on the political agenda, this book brings together studies of leading tax economists and lawyers to assess the various reform proposals and examine the effects of tax reform in several distinct areas. Together, these studies and comments on them present a balanced evaluation of professional opinion on the issues that will be critical in the tax reform debate. The book addresses annual and lifetime distributional effects, saving, investment, transitional problems, simplification, home ownership and housing prices, charitable groups, international taxation, financial intermediaries and insurance, labor supply, and health insurance. In addition to Henry Aaron and William Gale, the contributors include Alan Auerbach, University of California, Berkeley; David Bradford, Princeton University; Charles Clotfelter, Duke University; Eric Engen, Federal Reserve; Don Fullerton, University of Texas; Jon Gruber, Massachusetts Institute of Technology; Patric Hendershott, Ohio State; David Ling, University of Florida; Ronald Perlman, Covington & Burling; Diane Lim Rogers, Congressional Budget Office; John Karl Scholz, University of Wisconsin; Joel Slemrod, University of Michigan; and Robert Triest, University of California, Davis.

The last half of the 20th-century has seen a phenomenal increase in the volume and complexity of international business. Global economy allows multinationals to design their operations in a manner that may significantly reduce their taxes, particularly by taking advantage of tax incentives offered by many countries to attract geographically-mobile capital and activities. Since 1962, 19 countries have enacted specific statutory regimes to counteract the perceived abuse of controlled foreign companies located in tax havens. In three cases to date, controlled foreign company (CFC) legislation has been challenged in legal proceedings on the basis that it contravened a tax treaty. The author presents an in-depth analysis of the potential conflict between CFC legislation and tax treaties. The author also evaluates the potential conflict between the CFC legislation found in European Union countries and the EC Treaty. This comprehensive work should be of interest to international tax advisers.

Preface This book contains the proceedings of the International Tax Conference on the c- th th mon consolidated corporate tax base (CCCTB) that was held in Berlin on 15 - 16 may 2007. The conference was jointly organised by the German Federal Ministry of Finance, the Centre for European Economic Research (ZEW), Mannheim, and the Max Planck Institute (MPI) for Intellectual Property, Competition and Tax Law, Munich. More than 250 participants from all over Europe and other regions, scholars, politicians, business people and tax administrators, discussed the Eu- pean Commission's proposal to establish a CCCTB. Three panels of tax experts evaluated the common tax base with respect to structural elements, consolidation, allocation, international aspects and administration. The conference made clear that the CCCTB has the potential to overcome some of the most intriguing problems of corporate income taxation within the Common Market. Common tax accounting rules substantially reduce compliance and administrative costs. Consolidation of a group's profits and losses effects cro- border loss compensation which removes a major tax obstacle for European cro- border investment. At the same time, tax planning with respect to financing and transfer pricing is pushed back within the European Union. Moreover, as far as the CCCTB applies, member states are able to remove tax provisions that are targeted at cross border tax evasion and that might be challenged by the jurisdiction of the Eu- pean Court of Justice.