International tax reform: its effect on repatriation decisions of multinational corporations

1999 ◽  
Vol 8 (2) ◽  
pp. 337-353 ◽  
Author(s):  
Haroldene F Wunder
Author(s):  
Geoffrey Hale

The author addresses the politics of business taxation and international tax competition as an interactive series of two- (and sometimes multi-) level games embedded in broader debates over international competition for investment and the distribution of fiscal costs and benefits within Canada. Drawing on several international relations theories (neo-institutionalist, public choice, and realist), the author explores the evolution of Canada's business tax system in relation to the evolving systems of other major competitors for international investment, especially the United States--changes that are occurring as part of a wider effort to balance and integrate competing and overlapping objectives of domestic and international economic policies. The author summarizes the historical and contemporary context for international tax competition, particularly with respect to income shifting, macro- and micro-challenges of tax arbitrage, and the tradeoffs involved in managing the domestic politics of taxation. The author concludes by identifying the options available for maintaining domestic fiscal and policy flexibility while responding effectively to growing tax competition, as embodied in the US tax reform of 2017 and other shifts in policy that point to declining political commitment to an open economy paradigm among Canada's major trading partners.


Author(s):  
Daniel Godson Olika

International tax issues have never been at the forefront of international politics as they are today. This is due in large part to the realization that the current international tax system in existence allows multinational corporations to plan their taxes in such a way that they will be able to pay little or no taxes at all. They are able to do this through certain loopholes and gaps that currently exist in the system. These loopholes and gaps are seen as creating opportunities for taxpayers who are involved in cross-border activities to aggressively structure their activities to mitigate potential tax exposure or achieve no tax liabilities. They do this by exploiting; the hybrid-mismatch arrangements, shortcomings of the transfer pricing rules in jurisdictions where they operate and shifting profits from countries where their profits are made to countries with low tax rates. Consequently, some multinationals pay as little as five percent in corporate taxes, even as smaller domestic businesses pay up to 30 percent. The result of this activity is what is known as; base erosion and profit-shifting (BEPS) and it has the potential to deprive all countries of significant tax revenues. This rave debate and harsh criticism from the public influenced the intervention of the Organisation for Economic Co-operation and Development (OECD) to start its now famous BEPS Project. The OECD BEPS Project aims to provide governments or tax administrators with clear international solutions for fighting aggressive corporate tax planning strategies that artificially shift profits to locations where they are subjected to more favourable tax treatment. This paper shall address the various strands of the BEPS debate, the OECD BEPS project, the impact of the project in Africa and Nigeria. The next section shall address the various strands of the debate.


AJIL Unbound ◽  
2020 ◽  
Vol 114 ◽  
pp. 265-269
Author(s):  
Lilian V. Faulhaber

In her article, Mason concludes that politics – or “bargaining over national interests”— “will play a starring role in determining the outcomes” of the current digital tax project. In this essay, I apply public choice theory to the politics of international tax and argue that two questions can shape our understanding of international tax negotiations and therefore help us predict the outcomes of future international tax reform projects. First, what interests are country delegates representing? Second, how are countries using their involvement in international negotiations to represent these interests? The first question highlights that country delegates are often not defending some agreed-upon “national interest” but are instead often protecting the interests of particular political parties, industries, or taxpayers, which in turn means that interests can change over time and that some voices are missing from debates. The second question highlights that country delegates can engage in international tax negotiations in a variety of ways. They can try to limit what, if anything, the negotiations achieve; they can try to push for more expansive results; and they can use the negotiations to provide international support for their own country's laws. This essay focuses on one particular version of this third type of engagement, where delegates use their country's involvement in an international project to validate and legitimate an idea or proposal that may previously have had little support. I refer to this involvement as “international legitimation,” and I argue that the Organisation for Economic Co-operation and Development (OECD)/G20 Base Erosion and Profit Shifting (BEPS) Project shows that delegates who took this approach may have achieved the most long-term success in that their inclusion of little-known provisions or concepts in the international outputs of the BEPS Project ended up leading to these provisions and concepts being adopted by countries around the world.


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