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Corporate Taxation and the International Challenge

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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Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches

Series No. 4381, Munich. SOU2014:40, 2014. Neutral Bolagsskatt - För Ökad Effektivitet och Stabilitet. Slutbetänkande av Företagsskattekommittén. Statens offentliga utredingar, Stockholm. Statistisches Bundesamt, 2011. Fachserie 14 Reihe 4 - Finanzen und Steuern - Steuerhaushalt. Wiesbaden. Sylt C. and Reid C., 2011. Formula Money. Formula One’s Financial Performance Guide. CNC - Communication and Network Consulting, Wyndeham Grange, Southwick, West Sussex. US Department of Treasury, 1992. Integration of

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Corporate tax in an international environment – Problems and possible remedies

Nordic countries. Danish Journal of Economics 143, 433-447. Sørensen P.B. (2007) Can capital income taxes survive? And should they? CESifo Economic Studies 53, 172-228, Munich. Toder E. and Viard A. (2014), Major Surgery Needed: A Call for Structural Reform of the US Corporate Income Tax. Tax Policy Center Publications, April 4. 2014. http://www.taxpolicycenter.org/publications/url.cfm?ID=413090 US Department of Treasury (1992), Integration of the Individual and Corporate Tax System: Taxing Business Income Once. U

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Book reviews 2016

—especially when the taxpayer obtains a situation of double nontaxation. Three juridical strategies for combating double nontaxation are described. One of these is the use of national rules, especially GAARs, to prevent tax avoidance. It is the consequences of this strategy that will be further elaborated in the book. Another building block consists of questions regarding the intersection between international law and national law, especially with regard to interpretation in case of a conflict between the international and national law. The author states that the integration

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Responsible Investment: Taxes and Paradoxes

difficult to see tax issues to be included in the definitions. See e . g . COM(2011) 681 final (A renewed EU strategy 2011-14 for Corporate Social Responsibility), p. 3 (referring further to COM(2001) 366): “The European Commission has previously defined Corporate Social Responsibility (CSR) as ‘a concept whereby companies integrate social and environmental concerns in their business operations and in their interaction with their stakeholders on a voluntary basis.”’ See also http://ec.europa.eu/growth/industry/corporate-social-responsibility_en : “Companies can become

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The Nordic model of taxation and its influence in North America: Image and Reality

definitions emphasizing different aspects. Another website defines the term primarily in terms of economic integration prompting a Facebook comment “[and] [l]eaving millions of workers with heartache,” which the commenter attributes to Donald Trump, July 2, 2016. http://www.merriam-webster.com/dictionary/globalization (July 11, 2016). Blum Walter J. Kalven Harry Jr “The Uneasy Case for Progressive Taxation,” University of Chicago Law Review 19 417 1952 global linkages . . . and the growth of a global consciousness, hence to the consolidation of world society.” The

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Good Tax Governance: A Matter of Moral Responsibility and Transparency

(see §5), many people believe that multinationals tend not to pay their fair share (see, e . g ., Happé 2007 , Happé 2015 , UK HMRC 2012 ). In order to establish the actual meaning of this concept in tax practice and the elbow room it leaves to multinationals, public debate is necessary. Socially responsible companies should, therefore, be willing to discuss their tax planning, which demands certain openness on their part. Having said that, one could distinguish a substantive approach and a procedural approach to integrate tax planning into the CSR agenda. A

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When the international lawyers get to be heard – the story of tax treaty interpretation as told in Sweden

Interpretation” Netherlands International Law Review 65 133 154 cited as “Linderfalk, 2007b” Linderfalk, Ulf. 2008. “Who are ‘the parties’? Article 31 § 3(c) of the 1969 Vienna Convention, and the ‘Principle of Systemic Integration’ Revisited”. Netherlands International Law Review , 55: 343– 364, cited as “Linderfalk, 2008a” 10.1017/S0165070X08003434 Linderfalk Ulf 2008 “Who are ‘the parties’? Article 31 § 3(c) of the 1969 Vienna Convention, and the ‘Principle of Systemic Integration’ Revisited” Netherlands International Law Review 55 343 364 cited as “Linderfalk, 2008a

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Reforming capital gains taxation of intercorporate share realizations : a law and economics approach from a Nordic perspective

system should be developed in the future and what a future corporate capital gains taxation model could be. Economic integration takes place most efficiently between such countries, of which the cultural, linguistic and social background is similar and which are located near to each other. The common Nordic market area enhances the diversification of the production and export and strengthens the competitiveness of the companies of the area also outside the area. The capital gains tax system perspective is an important research focus because it would be valuable to the

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Eliminating the secondary earner bias. Policy lessons from the introduction of partial individual taxation in Sweden in 1971

was increased by 5 per cent, from 10 to 15 per cent. Ibid . p. 101. The regressive effects of this increase for lower income groups were compensated with increased social transfers such as child allowances and other family-related social benefits. This reflected a general ambition expressed in the reform to integrate the transfer and benefit system for families with the tax system. Ibid . p. 70 and pp. 73-74. The tax reform was also funded by increases in the inheritance and gift tax and the wealth tax. In line with the redistributive ambition of the reform, large

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