The Tests for the Determination of the Scope of Taxes: The Territorial Location of the Object and the Personal Link of the Taxpayer to the Country

1969 ◽  
Vol 4 (3) ◽  
pp. 392-416
Author(s):  
Aryeh Lapidoth
Keyword(s):  
Income Tax ◽  
Tax System ◽  
Income Approach ◽  
Similar Term

The scope of income tax is generally determined in the light of two criteria: the personal link of the taxpayer to the country and the link between the income and the territory of the country imposing the tax. The imposition of tax on the basis of the second of these criteria is known as “the source of the income” approach.A similar term, the doctrine of “source”, was used in the British income tax system to denote a different theory. That theory was based on the idea that all income must have a “source” and that no one ought to be taxed in a given year unless it can be shown that he had a source from which income could be derived during that year. It should be noted, however, that notwithstanding the linguistic resemblance between the terms used for the two theories, in fact they deal with different matters. Hence, though perhaps historically related, the two concepts should not be confused.

Peculiarities of the “Estonian” Tax Model in Taxation System of Georgia

2018 ◽  
Vol 4 (2) ◽  
pp. 156
Author(s):  
Besik Bolkvadze
Keyword(s):  
Income Tax ◽  
Economic Reforms ◽  
Transitional Economy ◽  
Corporate Income Tax ◽  
Business Sector ◽  
Tax System ◽  
Efficient Operation ◽  
Taxation System

Georgia is a country of a transitional economy, one of the most important financial determinants of which is the tax system, which is constantly undergoing the changes to different directions in terms of perfection and development. Taxes somehow create a peculiar "bridge" between the macrofinance and microfinance, among which the corporate income tax gains the function of the crucial important tax in terms of efficient operation of the business sector. Among the reforms carried out in the economy of Georgia, one of the most topical directions among the economic reforms is establishment of the so-called “Estonian” model and its further implementation. The present paper deals with the relative aspects of traditional and Estonian models of taxation and substantiates the necessity of determination of the main directions of its perfection.

scholarly journals Victory Tax: A Holistic Income Tax System

Entropy ◽  
2021 ◽  
Vol 23 (11) ◽  
pp. 1492
Author(s):  
Donald J. Jacobs
Keyword(s):  
Income Tax ◽  
Free Market ◽  
Poverty Line ◽  
The United States ◽  
Effective Tax Rate ◽  
Tax System ◽  
Tax Rate ◽  
Single Tax ◽  
Government Transfer ◽  
Log Normal

How can an income tax system be designed to exploit human nature and a free market to create a poverty free society, while balancing budgets without disproportional tax burdens? Such a tax system, with universal character, is deduced from the following guiding principles: (1) a single tax rate applies to all income types and levels; (2) the tax rate adjusts to satisfy budget projections; (3) government transfer only supplements the income of households with self-generated income below the poverty line; (4) deductions for basic living expenses, itemized investments and capital losses are allowed; (5) deductions cannot be applied to government transfer. A general framework emerges with three parameters that determine a minimum allowed tax deduction, a maximum allowed itemized deduction, and a maximum deduction defined by income percentage. An income distribution that mimics the United States, and a series of log-normal distributions are considered to quantitatively compare detailed characteristics of this tax system to progressive and flat tax systems. To minimize government dependency while maximizing after-tax income, the effective tax rate (ETR) as a function of income percentile takes the shape of the letter, V, inspiring the name victory tax, where the middle class has the lowest ETR.

scholarly journals Unified Reporting on Personal Income Tax and Unified Social Tax: Simplification or Additional Complication of Conditions for Business Operation?

2020 ◽  
pp. 48-54
Author(s):  
Andrii Boichuk ◽  
Keyword(s):  
Income Tax ◽  
Personal Income ◽  
Effective Control ◽  
Personal Income Tax ◽  
Tax System ◽  
Doing Business ◽  
Tax Simplification ◽  
Processing Information ◽  
Tax Payments ◽  
The Military

In the context of the reform of the tax system and the accounting and reporting system, as well as the integration of Ukraine with the European Community, the issue of simplifying the conditions for doing business, building an effective and understandable system for administering taxes and other duties acquire special significance. One of the important aspects of reforming the tax system of Ukraine is the introduction of unified reporting on personal income tax and unified social tax. The purpose of the article is to identify the positive and negative aspects of the process of reforming the reporting on personal income tax and unified social tax and scientifically substantiate the structure of such unified reporting. The existing forms of reporting on personal income tax and unified social tax, proposed by government agencies, were analyzed. In addition, the unified reporting models from these taxes proposed by scientists were critically assessed by the author. It was found that such indicators as the presence of Ukrainian citizenship, gender and the sign of a new job, do not participate in the process of monitoring the completeness of tax payments. Therefore, it is impractical to fill in these indicators for each employee, and it is enough to submit the total number and structure of these indicators on the reporting title page. The opposite situation exists with the military tax, which is advisable to display for each employee in the reporting for more effective control over its accrual and payment. The author has improved the structure of unified reporting on personal income tax and unified social tax, which will reduce the time spent on filling out such reports, increase the efficiency of control by the fiscal authorities and simplify the process of processing unified reporting data. The main advantages of the proposed form of unified reporting are: significant reduction in the number of indicators; simplicity and compactness; personalized registration of military tax; ease of filling and processing information.

scholarly journals Tax planning in Australia’s income tax system

2020 ◽  
Vol 27 (1) ◽  
pp. 59-83
Author(s):  
Tristram Sainsbury ◽  
Robert Breunig
Keyword(s):  
Income Tax ◽  
Tax Planning ◽  
Tax System

scholarly journals Does the Tax System Reduce Tax Evasion in Light of the Governance Mechanisms? Evidence From Jordan

2021 ◽  
Vol 12 (2) ◽  
pp. 99
Author(s):  
Ashraf Bataineh
Keyword(s):  
Tax Evasion ◽  
Income Tax ◽  
Social Impact ◽  
Positive Impact ◽  
Governance Mechanisms ◽  
Official Statistics ◽  
Tax System ◽  
Study Results ◽  
The Impact ◽  
Awareness Level

This study aims to measure the impact of tax system elements on reducing the tax evasion, in light of the governance mechanisms in Jordan. The study sample consists of (140) tax auditors at the Jordanian Income tax and sales department, and to achieve the study objectives the researcher designed a questionnaire and distributed it on the study sample members. Study results show that elements of the tax system (tax legislations, tax administration, and Taxpayer) have a positive impact on reducing the tax evasion, in light of governance mechanisms. study recommends the need to raise the tax awareness level among members of the Taxpayer, work to reduce the continuation of making adjustments on tax laws and legislation, and give a sufficient period of time to ensure that desired economic and social impact being achieved from these adjustments, with the need to announce the official statistics of tax evasion’s figures and ratios, because the unofficial statistics on tax evasion have been tarnished by some exaggeration where work should concentrate on increasing penalties of tax evaders.

scholarly journals The Double Irish and Dutch Sandwich tax strategies: Could a general anti-avoidance rule counteract the problems caused by the utilisation of these structures?

2021 ◽  
Author(s):  
◽  
Danielle Thorne
Keyword(s):  
United States ◽  
Income Tax ◽  
Multinational Enterprises ◽  
Current System ◽  
The United States ◽  
Tax System ◽  
Tax Havens ◽  
Intangible Resources ◽  
And Control ◽  
Tax Structures

<p>This paper analyses the Double Irish and Dutch Sandwich tax structures used by large multinational enterprises. These structures enable companies to shift significant profits to offshore tax havens through the use of wholly owned subsidiaries in Ireland and the Netherlands. Application of the New Zealand General Anti-Avoidance rule in s BG 1 of the Income Tax Act 2007 reveals that any attempt to counteract these structures would be highly fact dependent. The paper concludes that it would be possible to apply the rule, but that there would be practical difficulties in relation to enforceability of the Commissioner’s ruling. A similar result was reached when applying the United States General Anti-Avoidance rule. The attempted application of the General Anti-Avoidance rules reveals a fundamental flaw in the income tax system. That is, the inability of the current system to regulate and control intangible resources and technology based transactions.</p>

scholarly journals Opportunities for Simplification in the Personal Income Tax Systems of the Visegrad Countries

2020 ◽  
Vol 65 (4) ◽  
pp. 531-553
Author(s):  
Éva Bonifert Szabóné
Keyword(s):  
Income Tax ◽  
Policy Instruments ◽  
Degree Of Approximation ◽  
Personal Income ◽  
Tax Burden ◽  
Personal Income Tax ◽  
It Use ◽  
Tax System ◽  
Tax Systems ◽  
The Impact

Due to the numerous factors that can influence the impact of the tax system and redistribution, there is no single correct answer to the question of which composition of economic policy instruments needs to be applied to achieve a desired redistributive effect. The general aim of the study is to investigate in relation to the quantifiable parameters of income tax systems, whether the consideration of the aspects of fairness and justice does have an excessively negative effect on the simplicity of tax systems. The study investigates the possibilities of simplifying the personal income tax system’s composition in some Central and Eastern European countries, while tax burden curves of the system remain as constant as possible. To this end, the study sets up a theoretical, simplified tax model, the parameters of which are determined by a computer program, in order to generate tax burden curves corresponding most closely to the curves of the real tax system. Based on the analysis, it can be established that the theoretical system – in some cases with restrictions – provides a good approximation to the tax burden curves of the investigated countries. The chosen simple model has a good degree of approximation to a real system that does not have significant breakpoints in its tax burden curves, nor does it use a taxation method that fundamentally modifies the system (e.g., splitting). Practical examples help to understand that a complex personal income tax system in a given country is not necessarily the only possible solution to achieve a given tax burden curve, the function may be reproduced with a good approximation constructed from simpler basic elements.

scholarly journals Selective Fiscal Measures and the Definition of the Relevant Reference Framework in the Light of Cases C‑106/09 P, Commission v Gibraltar and C‑203/16 P, Heitkamp BauHolding v Commission

2020 ◽  
Vol 13 (2) ◽  
pp. 64-75
Author(s):  
Hanna-Mari Immonen
Keyword(s):  
Reference System ◽  
European Court Of Justice ◽  
Tax System ◽  
Reference Framework ◽  
Court Of Justice ◽  
European Court ◽  
Relevant Reference ◽  
Definition Of ◽  
State Aids

This article examines fiscal State aids and the selectivity condition. Assessing the selectivity is relatively complex in tax matters since it involves the analysis of the general tax system in which the regime under review applies. The focus of this article is on the selectivity analysis and the analysis of the general tax system i.e. the determination of the relevant reference framework. The definition of the relevant reference framework is still open to various interpretations despite the fact that the European Court of Justice has examined selectivity issues in several cases in the 2000s. The Gibraltar judgement has materially broadened the interpretation of the selectivity condition and the application of Article 107(1) TFEU. The Heitkamp BauHolding judgment confirms the interpretation adopted in the Gibraltar judgement, but also defines the scope of Article 107(1) TFEU in more detail. Yet the offset of the selectivity assessment i.e. the determination of the relevant reference system is still receptive to various interpretations.

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