Martin Ruf and Dirk Schindler
This paper presents the general design of thin-capitalization rules and summarizes the economic effects of such rules as identified in theoretical models. We review empirical studies providing evidence on the experience with (German) thin-capitalization rules as well as on the adjustment of German multinationals to foreign thin-capitalization rules. Special emphasis is given to the development in Germany, because Germany went a long way in limiting interest deductibility by enacting a drastic change in its thin-capitalization rules in 2008, and because superb German data on multinational finance allows for testing several aspects consistently. We then discuss the experience of the Nordic countries with thin-capitalization rules. Briefly reviewing potential alternatives as well, we believe that the arm’s-length principle is administratively too costly and impracticable, whereas we argue that controlled-foreign-company rules might be another promising avenue for limiting internal debt shifting. Fundamental tax reforms towards a system with either "allowance for corporate equity" (ACE) or a "comprehensive business income tax" (CBIT) should also eliminate any thin-capitalization incentive.
The paper addresses the problems of corporate taxation in a globalized world. It first considers recent trends in international practices and then reviews the literature on the effects of corporate taxes in closed and open economies. The paper emphasizes the severity of the problems caused by current international tax rules. It compares various national and international policy alternatives and considers two recent Nordic tax reform proposals as examples of national-level solutions. The problems of current international corporate taxation are fundamental. Introducing increasingly tight antiavoidance measures could serve as a medium-term approach but does not provide any promising long-term solution. There should be more research concerning initiatives that would reform the fundamental principles of the international tax system.
This paper examines the development of taxation in Sweden from 1862 to 2010. The examination includes six key aspects of the Swedish tax system, namely the taxation of labor income, capital income, wealth, inheritances and gifts, consumption and real estate. The importance of these taxes varied greatly over time and Sweden increasingly relied on broad-based taxes (such as income taxes and general consumption taxes) and taxes that were less visible to the public (such as payroll taxes and social security contributions). The tax-to-GDP ratio was initially low and relatively stable, but from the 1930s, the ratio increased sharply for nearly 50 years. Towards the end of the period, the tax-to-GDP ratio declined significantly.
Pernilla Rendahl and David Kleist
This article investigates if increasing neutrality between debt and equity capital might improve the efficiency in a corporate tax system. Firm-level and sector- level taxation data from Sweden is used to study if a tax system that is characterized by very few limitations with respect to the deductibility of interest costs leads to systematic differences in the taxes paid by different sectors. This paper finds that there are differences between different sectors’ tax payments and these differences can be explained by the sectors’ use of debt capital.
This article aims to give an overview of the rules concerning taxation of companies in Sweden and of trends in the taxation of companies that have been evident in the last few years. It focuses in particular on issues that are connected with the so-called BEPS discussion, for instance interest deduction limitations, CFC rules, general anti-avoidance rules and other rules intended to protect the national tax base. It also sets out to describe other important features of the Swedish tax legislation in regard to companies, such as the rules on taxation of inbound and outbound dividends, interest and royalty.