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This is an open access title available under the terms of a CC
BY-NC-ND 4.0 licence. It is offered as a free PDF download from OUP
and selected open access locations. This book undertakes a
fundamental review of the existing international system of taxing
business profit. It steps back from the current political debates
on how to combat profit shifting and how taxing rights over the
profits of the digitalized economy should be allocated. Instead, it
starts from first principles to ask how we should evaluate a tax on
business profit-and whether there is any good rationale for such a
tax in the first place. It then goes on to evaluate the existing
system and a number of alternatives that have been proposed. It
argues that the existing system is fundamentally flawed, and that
there is a need for radical reform. The key conclusion from the
analysis is that there would be significant gains from a reform
that moved the system towards taxing profit in the country in which
a business made its sales to third parties. That conclusion informs
two proposals that are put forward in detail and evaluated: the
Residual Profit Allocation by Income (RPAI) and the
Destination-based Cash Flow Tax (DBCFT). The book is authored by
group of economists and lawyers-the Oxford International Tax Group,
chaired by Michael P. Devereux. It draws insights from both
economics and law-including economic theory, empirical evidence on
the impact of taxes, and an examination of practical issues of
implementation-to assess the existing system and to consider
fundamental reforms. This book will be useful to tax policy makers,
tax professionals, academics, and anyone interested in tax policy.
This is an open access title available under the terms of a CC
BY-NC-ND 4.0 licence. It is offered as a free PDF download from OUP
and selected open access locations. This book undertakes a
fundamental review of the existing international system of taxing
business profit. It steps back from the current political debates
on how to combat profit shifting and how taxing rights over the
profits of the digitalized economy should be allocated. Instead, it
starts from first principles to ask how we should evaluate a tax on
business profit-and whether there is any good rationale for such a
tax in the first place. It then goes on to evaluate the existing
system and a number of alternatives that have been proposed. It
argues that the existing system is fundamentally flawed, and that
there is a need for radical reform. The key conclusion from the
analysis is that there would be significant gains from a reform
that moved the system towards taxing profit in the country in which
a business made its sales to third parties. That conclusion informs
two proposals that are put forward in detail and evaluated: the
Residual Profit Allocation by Income (RPAI) and the
Destination-based Cash Flow Tax (DBCFT). The book is authored by
group of economists and lawyers-the Oxford International Tax Group,
chaired by Michael P. Devereux. It draws insights from both
economics and law-including economic theory, empirical evidence on
the impact of taxes, and an examination of practical issues of
implementation-to assess the existing system and to consider
fundamental reforms. This book will be useful to tax policy makers,
tax professionals, academics, and anyone interested in tax policy.
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