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Peter Koerver Schmidt

Abstract

It is argued th**at the higher degree of economic integration across borders and the international trend towards a reduction of corporate income tax rates have had a significant impact on the Danish corporate tax regime in recent years. Accordingly, during the last ten years the Danish statutory corporate tax rate has been lowered further, while several government actions at the same time have been taken in order to combat international tax avoidance and evasion. As a result, new anti-avoidance provisions have been introduced and some of the older anti-avoidance provisions have been tightened in order to prevent base erosion and profit shifting. Thus, to some extent Denmark has already tried to address a number of the key pressure areas mentioned in the recently published OECD BEPS report, such as international mismatches in entity and instrument characterization, the tax treatment of related party debt financing, transfer pricing and the effectiveness of anti-avoidance measures. However, the article concludes that these anti-avoidance provisions often suffer from being quite complex, very broad in scope and open to criticism from an EU law perspective.

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Benn Folkvord and Michael Riis Jacobsen

Abstract

Although globalization has contributed immensely to growth and prosperity around the world, it is a growing challenge for tax policy makers. Globalization and greater mobility of tax bases increase the relative importance of taxes in corporations’ investment decisions. The combination of highly mobile capital, inadequacies in existing tax laws and a total change of international business environment have led to the fundamental problem in international tax law labeled by the OECD as the problem of BEPS (Base Erosion and Profit Shifting), along with severe competition among countries to attract investments and business activities. These challenges are the topic for the 2014 seminar of the Nordic Tax Research Council. Based on the Nordic national reports we discuss these challenges

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David Kleist and Pernilla Rendahl

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Dennis Ramsdahl Jensen

Abstract

The issue regarding output taxation, input deduction and determination of the place of taxation in VAT law is inextricably linked with a correct fact determination. This is also the case in relation to a delimitation of the individual tax subject including the question whether related subjects/units should be acknowledged as independent tax subjects, or whether they should qualify as one subject/ one unit in a legal VAT context instead. A coherent analysis of selected ECJ rulings of relevance for the delimitation of each tax subject shows that subject delimitation in national civil law also is the predominant basis in a legal VAT context unless the law contains explicit deviations from this or should be deviated from on the basis of either abuse of law or substance over form considerations. However, in this article it is proved that case C-388/11, Crédit Lyonnais breaks with this basic premise, as the ECJ in this case ignores the subject delimitation in civil law without a convincing argumentation for the fact that the law dictates this and without referring to abuse of law or substance over form.

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Magnus Henrekson and Gunnar Du Rietz

Abstract

We study the evolution of modern Swedish wealth taxation from its introduction in**1911 until it was abolished in 2007. The rules concerning valuation of assets, deductions/exemptions and tax schedules to characterize effective wealth tax schedules are described. These rules and schedules are used to calculate marginal and average wealth tax rates for three differently endowed owners of family firms and individual fortunes corresponding to a large, medium-sized and small firm. The overall trend in the direct wealth tax was rising until 1971 for owners of large and medium-sized firms and for individuals of equally-sized wealth consisting of non-corporate assets. Average direct wealth tax rates were low until 1934, except for 1913 when a progressive defense tax was levied. There were three major tax hikes: in 1934, when the wealth tax was more than doubled, in 1948 when tax rates were doubled again and in 1971 for owners of large firms and similarly sized non-corporate fortunes. Effective tax rates peaked in 1973 for owners of large firms and in 1983 for individuals with large non-corporate wealth. Reduction rules limited the wealth tax rates from 1934 for fortunes with high wealth/income ratios. The wealth tax on unlisted net business equity was abolished in 1991. Tax rates for wealthy individuals were decreased in 1991 and in 1992 and then remained at 0.5-1 percent through 2006, depending on whether the reduction rule was applicable. Tax rates for small-firm owners and small individual fortunes were substantially lower. Aggregate wealth tax revenues were rela-tively small; they never exceeded 0.4 percent of GDP in the postwar period and amounted to 0.16 percent of GDP in 2006.

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Jarkko Harju

Abstract

In this article I briefly describe the main questions related to the design of a tax system and introduce policy evaluation methods that can help us to learn about the effects of different taxes on different outcomes. Then I consider what various responses mean in terms of agents’ behavior and give my view of aspects that are important when tax systems are reformed. Finally I present the results of my PhD dissertation (Harju (2013)) and the contributions of the articles therein one by one, the aim being to offer examples of empirical tax research applying policy evaluation methods.

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Eleonor Kristoffersson

Abstract

Jag har fått uppdraget att recensera Roger Persson Östermans1 senaste verk. Redan inledningsvis vill jag framhålla att boken är välskriven och innehåller få redaktionella fel. Författaren ger klara uttryck för sin egen uppfattning, och därigenom blir boken särskilt läsvärd. Författaren är den förste sedan Sture Bergström (Förhandsbesked vid inkomsttaxering, Uppsala 1990) som tar ett större grepp om förhandsbeskedsfrågor.

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Frederik Zimmer

Abstract

With effect as from 1st January 2014 Norway abolished the inheritance tax and introduced the so-called continuity principle in income taxation. This means that heirs and receivers of gifts step into the tax basis and other tax positions of the giver and the deceased. Some additional requirements apply to some tax positions, in particular tax positions not related to assets (typically deferral of capital gains and carry forward of losses). Dwelling-houses and farms and forestries which the deceased or the giver could have sold without capital gains taxation is excepted.