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countermeasures. International Tax and Public Finance 22, 426-451. Blouin J., Huizinga H., Laeven L. and Nicodème G. (2013), Thin capitalization rules and multinational firm capital structure. Oxford University Centre for Business Taxation, WP 1323, Oxford. Boadway R. and Bruce N. (1984), A General Proposion on the Design of a Neutral Business Tax. Journal of Public Economics 24, 231-239. Bond S. and Devereux M.P. (2002), Cash flow taxes in an open economy. CEPR Discussion Paper 3401, London. Brøchner J., Jensen J., Svensson P. and Sørensen P.B. (2006), The Dilemmas of Tax

reliability in financial reporting. Highly reliable financial reports solely include realized cash flows, whereas highly relevant reports are concerned with the current value of expected future cash flows. Since accounting rules and legislation demand both relevance and reliability in proportion, financial reporting is therefore associated with certain elements of discretion and managerial judgment. Academic accounting literature provides many definitions of the term earnings management. Derived from the opportunistic use of discretion in financial reporting, early

capital more and more from abroad. Corporate income taxation should improve economic efficiency by encouraging entrepreneurship and by being competitive and assessable. Growth of capital flows is one of the key features of globalization. Investments, productivity and income have always also been important topics in the economics related discussions. Increasing the amount of capital is investing. Capital can be considered to be everything that is supporting business to generate profit. Technical progress of the country increases the productivity of capital, and country


assessed whether the current corporate tax base should still be used in light of the challenges identified. The Commission assessed several alternatives to the current system, including a cash flow tax, an al- lowance for corporate equity (the ACE model), or an abol- ishment of the deduction of interest (the CBIT model). Un- der a cash-flow tax, the tax base is the difference between inflows (receipts) and outflows (payments). The cash-flow Nordic News | 63 tax functions as a tax on the present value of the net cash flow. Even if it is taxed on a proportion of this net

tax Tax per profit and loss account Tax paid per cash flow Employees €m €m €m €m Danske Bank A/S 2017 CRD IV 10,244 3,533 725 725 19,769 Danske Bank A/S 2017 Accounts 6,473 3,534 724 737 19,768 Danske Bank A/S 2017 Difference 3,771 (1) 1 (12) 1 DNB ASA 2017 CRD IV 5,535 2,877 542 542 9,561 DNB ASA 2017 Accounts 5,487 2,882 542 1,156 9,561 DNB ASA 2017 Difference 48 (5) (0) (614) 0 Nordea Bank AB 2017 CRD IV 9,469 3,998 950 950 31,437 Nordea Bank AB 2017 Accounts 9,469 3,998 950 950 30,399 Nordea Bank AB 2017 Difference 0 0 0 0 1,038 Skandinaviska Enskilda Banken AB

-Yonah, Clausing & Durst, Allocating Business Profits for Tax Purposes: A Proposal to Adopt a Formulary Profit Split, 9 Fla. Tax Rev. 497 (2009). In recent years, DBCT has attracted some support by economists, such as Alan Auerbach and Mike Devereux . 24 Auerbach, Devereux and Simpson, Taxing Corporate Income, NBERWorking Paper 14494 (2008); Devereux and de la Feria, Designing and Implementing a Destination-Based Corporate Tax, WP 14/07 (May 2014). While the economists tend to advocate a cash flow DBCT, i. e ., a corporate tax that is more consumption than income based because

an omission on the part of the officer or that the officer has not acted correctly from the taxpayer’s perspective (Quist and Fransson ( 2013 , 2015 )). 6 The concept failure demand was introduced by Seddon in I want you to cheat!: The unreasonable guide to service and quality in organisations (1992). It should be stressed that the concept failure demand has an imprecise meaning, which makes application difficult. Public agencies tend to regard the flow of incoming matters as given. Productivity can, for instance, be measured in the number of incoming calls

investments depends on corporations’ access to capital. If capital flows freely across borders domestic taxation of personal capital income does not directly affect the level of real investments made by corporations in Denmark if the marginal investment incen- tive is determined by e.g. an overseas pension fund, another foreign investor or if domestic investors compare the return on domestic equi- ty to similar foreign assets. In this case, domestic capital income taxa- tion affects the level of household savings but not business invest- ment. A criticism of the

from Belgium is of equal size, and around 35 percent of the outstanding inbound FDI is in special purpose vehicles (referred to as “captive financial institutions and money lenders” in the national accounts) ( Duprez and Van Nieuwenhuyze, 2016 ). This suggests that a large share of FDI comprises purely financial flows running through Belgium—rather than greenfield investments that contribute to the Belgian economy. These financial flows may be a part of the tax planning strategies by MNCs and create negative spillovers on the tax base of other countries. The tax

majority of cases, concede the issue.” HMRC, Litigation and Settlement Strategy , 2017, p.7, available at archived at . Indeed, “In general, HMRC will not take up a tax dispute unless the overall revenue flows potentially involved justify doing so” ibid p 17. and a dispute that it is likely to lose does not promise much by way of revenue flows. The foregoing has serious implications as regards the