Unitary Taxation and International Tax Rules

unitary taxation; tax; international tax; formulary apportionment; separate accounting; arm’s length standard; developing countries; multinational companies.Any proposal for adoption of a unitary tax (UT) system ought to clear the first and most common hurdle of its compatibility, or lack of it, with the current norms in the international tax system – specifically, the current tax treaty network. This paper argues that unitary taxation is compatible with most of the current bilateral tax treaties and local countries’ national tax laws. The first argument levelled against UT is the revision of the United States (US) and Organisation for Economic Co-operation and Development (OECD) model tax treaties to specifically exclude application of UT through formulary apportionment. However, this argument carries little to no weight because most tax treaties currently outstanding, including those signed as recently as 2011 and even involving the US, do not adopt the changes and still contain Article 7 language allowing for a unitary approach. Another argument for incompatibility is that separate accounting (SA) and arm’s length standard (ALS) are so enshrined in tax treaties that they have become some sort of international law that is binding even when not explicitly stated. This argument, again, has no merit. On the one hand, it is well established that tax treaties, specifically model tax treaties, do not create a right to tax and cannot create a binding rule of law, even international law. On the other hand, and assuming the wide embodiment of SA into the treaties creates some sort of international binding norm, the same argument would hold for UT because the Article 7(4) language that authorises UT is still very present in most tax treaties currently outstanding. We acknowledge that a complete transition from SA to UT would be a long-term process requiring major revisions across the international tax regime; however, it is our view that countries in general, and developing countries in particular, can legally apply UT because it is in compliance with both the tax treaties they have signed, if any, and their national laws.DfID, NORA

Formulary Apportionment and International Tax Rules

Any proposal to adopt unitary taxation (UT) of multinationals has to contend with whether such taxation is compatible with existing international tax rules, and, in particular, with the bilateral tax treaty network. Indeed, some researchers have argued that the separate accounting (SA) method and the arm’s length standard (ALS), introduced in the early twentieth century, are so embodied in the treaties that they form part of customary international law, and are binding even in the absence of a treaty. We disagree, because the unitary approach is just as widely embodied in most of the current international tax treaties, and, where there are no treaties, national laws allow for a unitary approach to taxation. In this chapter we will argue that UT can be compatible with most existing tax treaties, and that developing countries, in particular, can implement it in most cases with or without a tax treaty and in accordance with their domestic laws

Hearing Feelings: Affective Categorization of Music and Speech in Alexithymia, an ERP Study

Background: Alexithymia, a condition characterized by deficits in interpreting and regulating feelings, is a risk factor for a variety of psychiatric conditions. Little is known about how alexithymia influences the processing of emotions in music and speech. Appreciation of such emotional qualities in auditory material is fundamental to human experience and has profound consequences for functioning in daily life. We investigated the neural signature of such emotional processing in alexithymia by means of event-related potentials. Methodology: Affective music and speech prosody were presented as targets following affectively congruent or incongruent visual word primes in two conditions. In two further conditions, affective music and speech prosody served as primes and visually presented words with affective connotations were presented as targets. Thirty-two participants (16 male) judged the affective valence of the targets. We tested the influence of alexithymia on cross-modal affective priming and on N400 amplitudes, indicative of individual sensitivity to an affective mismatch between words, prosody, and music. Our results indicate that the affective priming effect for prosody targets tended to be reduced with increasing scores on alexithymia, while no behavioral differences were observed for music and word targets. At the electrophysiological level, alexithymia was associated with significantly smaller N400 amplitudes in response to affectively incongruent music and speech targets, but not to incongruent word targets. Conclusions: Our results suggest a reduced sensitivity for the emotional qualities of speech and music in alexithymia during affective categorization. This deficit becomes evident primarily in situations in which a verbalization of emotional information is required

Multiple Sclerosis Decreases Explicit Counterfactual Processing and Risk Taking in Decision Making

Deficits in decision making (DM) are commonly associated with prefrontal cortical damage, but may occur with multiple sclerosis (MS). There are no data concerning the impact of MS on tasks evaluating DM under explicit risk, where different emotional and cognitive components can be distinguished.Methods: We assessed 72 relapsing-remitting MS (RRMS) patients with mild to moderate disease and 38 healthy controls in two DM tasks involving risk with explicit rules: (1) The Wheel of Fortune (WOF), which probes the anticipated affects of decisions outcomes on future choices; and (2) The Cambridge Gamble Task (CGT) which measures risk taking. Participants also underwent a neuropsychological and emotional assessment, and skin conductance responses (SCRs) were recorded.Results: In the WOF, RRMS patients showed deficits in integrating positive counterfactual information (p <0.005) and greater risk aversion (p <0.001). They reported less negative affect than controls (disappointment: p = 0.007; regret: p = 0.01), although their implicit emotional reactions as measured by post-choice SCRs did not differ. In the CGT, RRMS patients differed from controls in quality of DM (p = 0.01) and deliberation time (p = 0.0002), the latter difference being correlated with attention scores. Such changes did not result in overall decreases in performance (total gains).Conclusions: The quality of DM under risk was modified by MS in both tasks. The reduction in the expression of disappointment coexisted with an increased risk aversion in the WOF and alexithymia features. These concomitant emotional alterations may have implications for better understanding the components of explicit DM and for the clinical support of MS patients

Brain connectivity changes occurring following cognitive behavioural therapy for psychosis predict long-term recovery

Little is known about the psychobiological mechanisms of cognitive behavioural therapy for psychosis (CBTp) and which specific processes are key in predicting favourable long-term outcomes. Following theoretical models of psychosis, this proof-of-concept study investigated whether the long-term recovery path of CBTp completers can be predicted by the neural changes in threatbased social affective processing that occur during CBTp. We followed up 22 participants who had undergone a social affective processing task during functional magnetic resonance imaging along with self-report and clinician-administered symptom measures, before and after receiving CBTp. Monthly ratings of psychotic and affective symptoms were obtained retrospectively across 8 years since receiving CBTp, plus self-reported recovery at final follow-up. We investigated whether these long-term outcomes were predicted by CBTp-led changes in functional connections with dorsal prefrontal cortical and amygdala during the processing of threatening and prosocial facial affect. Although long-term psychotic symptoms were predicted by changes in prefrontal connections during prosocial facial affective processing, long-term affective symptoms were predicted by threat-related amygdalo-inferior parietal lobule connectivity. Greater increases in dorsolateral prefrontal cortex connectivity with amygdala following CBTp also predicted higher subjective ratings of recovery at long-term follow-up. These findings show that reorganisation occurring at the neural level following psychological therapy can predict the subsequent recovery path of people with psychosis across 8 years. This novel methodology shows promise for further studies with larger sample size, which are needed to better examine the sensitivity of psychobiological processes, in comparison to existing clinical measures, in predicting long-term outcomes.Wellcome Trust; Biomedical Research Centre for Mental Health at the Institute of Psychiatry, Psychology & Neuroscience, King’s College London and South London and Maudsley NHS Foundation Trust, U

From Avoiding ‘Double Taxation’ Yesterday to Avoiding ‘Double Non-Taxation’ Today: The Urgent Need for an International Tax Regime Based on Unitary Tax Principles

The purpose of this Dissertation is to analyze the current ills of the international tax system with a special focus on developing countries, and to structure and present a Unitary Taxation System (“UT”) as a solution to the legitimate and multifaceted complaints about current international taxation of multinational companies (“MNEs”). The research aims at presenting a UT that would restore credibility in the international tax arena by providing fiscal predictability and certainty to MNEs, and ensuring appropriate taxation by all countries (specifically developing nations) of all “real” economic activity within their borders. Although this issue has been previously explored, there is currently a vacuum to be filled concerning a coherent and complete UT as an alternative to the current taxation of MNEs from a developing countries’ perspective. Specifically, there is a need for a major research and elaboration of a specific UT that would satisfy the legitimate concerns of developing countries while not alienating the developed world and MNEs. That is the goal of this Dissertatio

Bases neurales de la perception de la menace chez l'homme (ce que nous apprend l'alexithymie sur le fonctionnement de ces réseaux)

Détecter des signaux de menace dans le comportement d autrui est crucial à l interaction sociale mais également à la survie de l individu. Les circuits cérébraux qui sous-tendent cette fonction commencent tout juste à émerger. A travers ce projet de thèse, nous avons cherché à décrypter les réseaux neuronaux en jeu dans la perception d expressions corporelles de peur et de colère, en explorant la façon dont un trait de personnalité, l alexithymie, connu pour être impliqué dans des déficits d introspection, de réactivité et de régulation émotionnelles, modulait la réponse et la connectivité des structures au sein de ces réseaux, à l aide de l imagerie par résonance magnétique fonctionnelle (IRMf). Nous avons observé que seule la réponse des structures préfrontales était modulée par le niveau d alexithymie des individus. En outre, nous avons révélé une connectivité fonctionnelle particulière : 1) entre le cortex cingulaire antérieur (ACC) et le cortex prémoteur (PM), chez les alexithymiques et en particulier chez des individus reportant des capacités réduites de réactivité émotionnelle ; 2) entre le cortex préfrontal ventro-médian (vmPFC) et l hypothalamus (HYP), la substance grise périaqueducale (PAG) et PM, chez les lexithymiques, et en particulier chez des individus reportant de bonnes capacités à réagir en situations stressantes. Nous pensons que l ACC jouerait un rôle dans la suppression de la réactivité émotionnelle, à l origine de la froideur affective observée chez les alexithymiques, tandis que le vmPFC jouerait un rôle dans l orchestration d une réponse adaptée au contexte en agissant sur les centres de la réponse autonome (HYP, PAG) et sur PMPARIS-BIUSJ-Physique recherche (751052113) / SudocSudocFranceF

Comprendre les actions, émotions et états mentaux d’autrui : psychologie et neurosciences

Notre capacité à interagir avec les autres repose en partie sur notre aptitude à prendre en compte leur point de vue. Considérer la perspective d’autrui est d’autant plus cruciale chez les humains, qui forment une espèce hautement sociale, où chaque individu dépend des autres pour coopérer et augmenter ses chances de survie. Comment se caractérise la « prise de perspective » ? Elle est souvent définie comme « la tendance à spontanément adopter le point de vue psychologique des autres » et à i..

Formulary Apportionment and International Tax Rules

Any proposal to adopt unitary taxation (UT) of multinationals has to contend with whether such taxation is compatible with existing international tax rules, and, in particular, with the bilateral tax treaty network. Indeed, some researchers have argued that the separate accounting (SA) method and the arm’s length standard (ALS), introduced in the early twentieth century, are so embodied in the treaties that they form part of customary international law, and are binding even in the absence of a treaty. We disagree, because the unitary approach is just as widely embodied in most of the current international tax treaties, and, where there are no treaties, national laws allow for a unitary approach to taxation. In this chapter we will argue that UT can be compatible with most existing tax treaties, and that developing countries, in particular, can implement it in most cases with or without a tax treaty and in accordance with their domestic laws