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Abstract

From an economic perspective a partnership is an odd construction. Generally, an economist will distinguish between physical persons and companies. However, partnerships are a combination of a person and a company. This report will attempt to give an overview of how the taxation of partnerships affects the organization of businesses and the role played by partnerships in the business structure in the Nordic countries.

The Economic General Report is based on the Economic National Reports from Denmark, Sweden, Norway, and Iceland. This report will include relevant information from the four reports. It is not an exhaustive study of the effects of the tax treatment of partnerships. However, it will examine how taxation of partnerships changes the incentive to choose a certain form of organization and it will give an illustration on how the different tax rules in the Nordic countries work. Particularly, it seeks to identify asymmetries in the taxation of different types of company structures, and the role of partnerships in the business structure.

Abstract

The general rule in EU law is that value-added tax (VAT) is to be levied on all goods and services. There are a number of exceptions, however, one of which applies to certain medical services. This paper examines the legal basis for tax exemptions in EU VAT law and in Swedish law, with particular attention to the extent to which the rapidly growing private health-care sector is covered by these tax exemptions.

Abstract

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.

Abstract

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.

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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

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.

Abstract

We study the development in the Danish corporate income tax base and the corporate income tax revenue in the period from 1990 until present. Measured in per cent of GDP the CIT base has out-paced the revenue due to parallel CIT rate cuts and base broadening reforms. We seek to explain the development in the CIT base and discuss whether this is threatened by base erosion and profit shifting.

Describing the development in the CIT tax base is a comprehensive and complex task and to pin-point one single cause is not possible. But it is possible to point to elements which have contributed to the development. We conclude that there exists a challenge in terms of international tax competition but find no evidence of the Danish CIT base suffering from this. The challenge for policy makers is designing a tax system which on one side secures sufficient revenue and on the other hand is internationally competitive.