Rationale underlying the Treasury proposals

Tax reform ; Taxation

Transfer Pricing and Tax Havens: Mending the LDC Revenue Net

The paper deals primarily with the use of transfer pricing and tax havens by multinational businesses to defer, avoid, or (depending on whether one views manipulation of transfer prices as involving avoidance or evasion) evade taxes levied by the country of residence. Thus it pays relatively little attention to the use of tax havens by wealthy individuals to evade taxes in their countries of residence. Nor does it consider preferential tax treatment for selected non-financial sectors, perhaps limited to foreign investors, in order to attract real (non-financial) activities. Such countries are not ordinarily called tax havens, and these policies are best covered by a paper on tax incentives. Finally, it does not consider headquarters havens, except in passing, in the brief discussion of corporate inversions.Working Paper Number 04-45

A consumption-based direct tax for countries in transition from socialism

This paper suggests a consumption-based direct tax, referred to here as a simplified alternative tax or SAT, as an alternative to the standard income tax for reforming socialist economies (RSEs). The paper consists of seven sections. Section I serves as an introduction. Section II outlines some of the objectives of tax policy in RSEs and some of the constraints on the achievement of those objectives. Section III provides examples of the overwhelming complexity of the income tax. Section IV explains the basic mechanics of the SAT and contrasts the simplicity of the SAT with the complexity of the income tax. Section V describes the economic advantages of the SAT and section VI discusses some potential problems of the SAT. The final section concludes by stating that the SAT encourages saving and investment in a way that is economically neutral and avoids many of the administrative problems of an income tax.Environmental Economics&Policies,Economic Theory&Research,Public Sector Economics&Finance,Banks&Banking Reform,International Terrorism&Counterterrorism

Does Sales-only Apportionment of Corporate Income Violate the GATT?

There has been a pronounced change in the formulas states use to apportion the income of multistate corporations from one that placed equal weight on payroll, profits, and sales to one that places at least half the weight on sales, and eight base apportionment solely on sales. This paper, which is intended to stimulate further analysis and debate, rather than provide a definitive conclusion, suggests that sales-only apportionment may violate the provisions of the General Agreement on Tariffs and Trade (the GATT) that prohibits export subsidies.

Implementing direct consumption taxes in developing countries

This report examines the possibility of using a direct tax on consumption as a replacement for an existing income tax within the context of a developing country. The structural differences between income and consumption taxes are described, and some simple examples are used to illustrate the basic differences in the taxation of businesses and individuals under the two approaches. The report includesa brief survey of the extensive literature on the choice between income and consumption as the basis for a system of direct taxation. After a detailed discussion of the choice between cash flow and tax prepayment treatment at the individual level under a direct consumption tax, the analysis concludes that for simplicity reasons the individual tax prepayment approach is the more appropriate one in the developing country context. The report then describes the structure and implementation of such a direct consumption tax. The discussion includes an examination of international and transitional issues, and also comments on the desirability and feasibility of supplementary wealth taxes and taxation on a presumptive basis.Environmental Economics&Policies,Economic Theory&Research,Public Sector Economics&Finance,Banks&Banking Reform,International Terrorism&Counterterrorism