scholarly journals Taking More than They Give: MNE Tax Privateering and Apple's “Ocean” Income

2018 ◽  
Vol 19 (4) ◽  
pp. 693-726
Author(s):  
Robin F. Hansen
Keyword(s):  
Action Plan ◽  
Multinational Enterprise ◽  
State Aid ◽  
The Self ◽  
The European Union ◽  
Profit Shifting ◽  
Complex State ◽  
Arm’S Length Principle ◽  
Self Interest ◽  
Face Complex

Following a three-year investigation, on August 30, 2016, the European Commission (EC) released its decision in the Ireland-Apple State aid case. The EC found that Ireland had breached the Treaty on the Functioning of the European Union because the manner in which Ireland had determined the tax payable by two Apple subsidiaries was not consistent with the arm's length principle and/or it was not based on objective criteria. This meant that Ireland had selectively favored Apple and provided the firm with State aid. The EC decision provides an example of how aggressive multinational enterprise (MNE) tax minimization is anti-competitive. The Ireland-Apple case also provides an illustration of how a lack of transparency and incoherency in MNE definition contribute to aggressive MNE tax minimization. States' reactions to the EC decision are further telling because they show how MNE tax minimization engages the self-interest of States. This suggests that efforts to combat aggressive MNE tax minimization, such as the OECD's Base Erosion and Profit-Shifting Action Plan, face complex State motivations in effecting change on the international level. Profit haven States have the most to lose if MNE tax minimization is effectively addressed. In addition, MNE home States may be at times loath to support changes to the system which favors “their” MNEs at the expense of other States' tax revenues. It is as if some home States view MNEs as their privateers, with such MNEs operating internationally under the tacit approval of their home States to aggressively avoid paying taxes to other countries. Home State leadership may be mistaken in thinking that MNE tax minimization is in their favor because MNEs are largely free agents and aggressive MNE tax minimization is dearly costing nearly all states.

Der OECD-Aktionsplan gegen die Steuervermeidung multinationaler Unternehmen – eine ordnungsökonomische Analyse der Maßnahmen und Reformoptionen

2015 ◽  
Vol 64 (2) ◽  
Author(s):  
Marco C. Melle
Keyword(s):  
European Union ◽  
Action Plan ◽  
Tax Avoidance ◽  
Multinational Companies ◽  
Constitutional Economics ◽  
The European Union ◽  
Profit Shifting ◽  
Corporation Tax ◽  
National Corporation ◽  
Avoidance Strategies

AbstractOn July, 19th, 2013 the OECD published an „Action Plan on Base Erosion and Profit Shifting“, a catalogue of 15 actions against the tax avoidance strategies of multinational companies. The intention of the present paper is to investigate and evaluate if such a coordination of the national policies is necessary from a constitutional economics perspective. The thesis is that the planned actions against the tax avoidance strategies of multinational companies can strengthen the relation of the national corporation tax revenues to the use of public goods. However, the question arises if for interest and royalty payments an international coordinated withholding taxation would not be preferable and if the European Union additionally should not agree on a common assessment base for corporate taxation.

Category of Market Price in Modern Tax Law

2016 ◽  
Vol 4 (7) ◽  
pp. 0-0
Author(s):  
Инна Хаванова ◽  
Inna Khavanova
Keyword(s):  
Transfer Pricing ◽  
Action Plan ◽  
Market Price ◽  
Profit Shifting ◽  
Complex Issue ◽  
Regulatory Changes ◽  
Pricing Rules ◽  
Arm’S Length Principle ◽  
The Difference ◽  
Correct Application

The article is devoted to transfer pricing rules with particular reference to unresolved problems. Its purpose is to outline the complex issue of transfer pricing. The author examines the difference between the concepts of “market price” and price, determined according to the “arm’s length principle”, discusses the basic rules of taxation, principles of determining the price of goods, work or services for taxation purposes. To ensure the correct application of the separate entity approach, countries have adopted the arm´s length principle. This article analyzes initiatives on taxation in the area of corporate taxation (OECD Action Plan on Base Erosion and Profit Shifting (BEPS), Final Reports “Aligning Transfer Pricing Outcomes with Value Creation”). The author points out that the level of control (direct or indirect) in determining interdependence between persons, has its own specific features in different states. The reason behind it is that the problem of transfer pricing does not always arise, but only when subjects establish specific relations. The article characterizes the regulatory changes and developments in Russia.

E-health developments in the system of health services in Hungary and the European Union

2014 ◽  
Vol 155 (21) ◽  
pp. 822-827
Author(s):  
Ágnes Váradi
Keyword(s):  
Health Care ◽  
European Union ◽  
Public Discourse ◽  
Action Plan ◽  
Fundamental Rights ◽  
Public Health Care ◽  
The European Union ◽  
Contemporary Issue ◽  
Definition Of ◽  
Basic Features

The question of electronic solutions in public health care has become a contemporary issue at the European Union level since the action plan of the Commission on the e-health developments of the period between 2012 and 2020 has been published. In Hungary this issue has been placed into the centre of attention after a draft on modifications of regulations in health-care has been released for public discourse, which – if accepted – would lay down the basics of an electronic heath-service system. The aim of this paper is to review the basic features of e-health solutions in Hungary and the European Union with the help of the most important pieces of legislation, documents of the European Union institutions and sources from secondary literature. When examining the definition of the basic goals and instruments of the development, differences between the European Union and national approaches can be detected. Examination of recent developmental programs and existing models seem to reveal difficulties in creating interoperability and financing such projects. Finally, the review is completed by the aspects of jurisdiction and fundamental rights. It is concluded that these issues are mandatory to delineate the legislative, economic and technological framework for the development of the e-health systems. Orv. Hetil., 2014, 155(21), 822–827.

European experience in transition to circular economy

2020 ◽  
Vol 19 (4) ◽  
pp. 598-617 ◽  
Author(s):  
S.V. Ratner
Keyword(s):  
European Union ◽  
Circular Economy ◽  
Raw Materials ◽  
Action Plan ◽  
National Level ◽  
The European Union ◽  
Scientific Methods ◽  
European Experience ◽  
General Scientific ◽  
The Eu

Subject. The article considers the concept of circular economy, which has originated relatively recently in the academic literature, and is now increasingly recognized in many countries at the national level. In the European Union, the transition to circular economy is viewed as an opportunity to improve competitiveness of the European Union, protect businesses from resource shortages and fluctuating prices for raw materials and supplies, and a way to increase employment and innovation. Objectives. The aim of the study is to analyze the incentives developed by the European Commission for moving to circular economy, and to assess their effectiveness on the basis of statistical analysis. Methods. I employ general scientific methods of research. Results. The analysis of the EU Action Plan for the Circular Economy enabled to conclude that the results of the recent research in circular economy barriers, eco-innovation, technology and infrastructure were successfully integrated into the framework of this document. Understanding the root causes holding back the circular economy development and the balanced combination of economic and administrative incentives strengthened the Action Plan, and it contributed to the circular economy development in the EU. Conclusions. The measures to stimulate the development of the circular economy proposed in the European Action Plan can be viewed as a prototype for designing similar strategies in other countries, including Russia. Meanwhile, a more detailed analysis of barriers to the circular economy at the level of individual countries and regions is needed.

scholarly journals Circular Bioeconomy Business Models to Overcome the Valley of Death. A Systematic Statistical Analysis of Studies and Projects in Emerging Bio-Based Technologies and Trends Linked to the SME Instrument Support

2021 ◽  
Vol 13 (4) ◽  
pp. 1899
Author(s):  
Fabiana Gatto ◽  
Ilaria Re
Keyword(s):  
Circular Economy ◽  
Success Factors ◽  
Business Models ◽  
Raw Materials ◽  
Action Plan ◽  
Future Perspective ◽  
The European Union ◽  
Strategic Orientations ◽  
Start Ups ◽  
Valley Of Death

Reducing the environmental pressure along the products life cycle, increasing efficiency in the consumption of resources and use of renewable raw materials, and shifting the economic system toward a circular and a climate-neutral model represent the heart of the current macro-trends of the European Union (EU) policy agendas. The circular economy and bioeconomy concepts introduced in the EU’s Circular Economy Action Plan and the Bioeconomy Strategy support innovation in rethinking economic systems focusing on market uptaking of greener solutions based on less-intensive resource consumption. In recent decades, industrial research has devoted enormous investments to demonstrate sustainable circular bio-based business models capable of overcoming the “Valley of Death” through alternative strategic orientations of “technological-push” and “market-pull”. The study highlights industrial research’s evolution on bio-based circular business model validation, trends, and topics with particular attention to the empowering capacity of start-ups and small and medium-sized enterprises (SMEs) to close the loops in renewable biological use and reduce dependence on fossil fuels. The research methodology involves a bibliographic search based on the Preferred Reporting Items for Systematic Reviews and Meta-Analyses (PRISMA) approach and the European Innovation Council (EIC) Accelerator Data Hub investigation to understand SMEs’ key success factors and start-ups of the circular bioeconomy sector. Eco and bio-based materials, nutraceuticals, and microalgae represent the most sustainable industry applications, leading to circular bioeconomy business models’ future perspective.

scholarly journals Towards a Circular Economy Taxation Framework: Expectations and Challenges of Implementation

2021 ◽  
Author(s):  
Leonidas Milios
Keyword(s):  
Circular Economy ◽  
Action Plan ◽  
Policy Instruments ◽  
Policy Instrument ◽  
Detailed Examination ◽  
Raw Material ◽  
The European Union ◽  
Material Resource ◽  
Waste Hierarchy ◽  
Tax Relief

AbstractThe transition to a circular economy is a complex process requiring wide multi-level and multi-stakeholder engagement and can be facilitated by appropriate policy interventions. Taking stock of the importance of a well-balanced policy mix that includes a variety of complementing policy instruments, the circular economy action plan of the European Union (COM(2020) 98 final) includes a section about “getting the economics right” in which it encourages the application of economic instruments. This contribution presents a comprehensive taxation framework, applied across the life cycle of products. The framework includes (1) a raw material resource tax, (2) reuse/repair tax relief, and (3) a waste hierarchy tax at the end of life of products. The research is based on a mixed method approach, using different sources to analyse the different measures in the framework. More mature concepts, such as material resource taxes, are analysed by reviewing the existing literature. The analysis of tax relief on repairs is based on interviews with stakeholders in Sweden, where this economic policy instrument has been implemented since 2017. Finally, for the waste hierarchy tax, which is a novel proposition in this contribution, macroeconomic modelling is used to analyse potential impacts of future implementation. In all cases, several implementation challenges are identified, and potential solutions are discussed according to literature and empirical sources. Further research is required both at the individual instrument and at the framework level. Each of the tax proposals needs a more detailed examination for its specificities of implementation, following the results of this study.

scholarly journals Environmental Consequences of Closing the Textile Loop—Life Cycle Assessment of a Circular Polyester Jacket

2021 ◽  
Vol 11 (7) ◽  
pp. 2964
Author(s):  
Gregor Braun ◽  
Claudia Som ◽  
Mélanie Schmutz ◽  
Roland Hischier
Keyword(s):  
Life Cycle Assessment ◽  
Life Cycle ◽  
Environmental Impacts ◽  
Circular Economy ◽  
Textile Industry ◽  
System Analysis ◽  
Action Plan ◽  
The European Union ◽  
Environmental Consequences ◽  
Energy And Material Flows

The textile industry is recognized as being one of the most polluting industries. Thus, the European Union aims to transform the textile industry with its “European Green Deal” and “Circular Economy Action Plan”. Awareness regarding the environmental impact of textiles is increasing and initiatives are appearing to make more sustainable products with a strong wish to move towards a circular economy. One of these initiatives is wear2wearTM, a collaboration consisting of multiple companies aiming to close the loop for polyester textiles. However, designing a circular product system does not lead automatically to lower environmental impacts. Therefore, a Life Cycle Assessment study has been conducted in order to compare the environmental impacts of a circular with a linear workwear jacket. The results show that a thoughtful “circular economy system” design approach can result in significantly lower environmental impacts than linear product systems. The study illustrates at the same time the necessity for Life Cycle Assessment practitioners to go beyond a simple comparison of one product to another when it comes to circular economy. Such products require a wider system analysis approach that takes into account multiple loops, having interconnected energy and material flows through reuse, remanufacture, and various recycling practices.

Levels and types of breaking the maxims: A neo-Gricean account of humor

2015 ◽  
Vol 12 (2) ◽  
Author(s):  
Attila L. Nemesi
Keyword(s):  
Conceptual Framework ◽  
The Self ◽  
Social Psychological ◽  
Cooperative Principle ◽  
Pragmatic Theory ◽  
Self Interest ◽  
Constant Tension

AbstractOn the basis of examples drawn from seven classic Hungarian film comedies, I argue in this article that the place of humor within the Gricean–Leechian model needs to be revisited and extended towards social psychological pragmatics to account for a wider range of humorous material. Scrutinizing the relevant controversial details of Grice’s conceptual framework, my concern is to find a practical way of fitting the various forms of humor into an adequate (and not an idealistic) pragmatic theory. I propose to differentiate between two levels and five types of breaking the maxims, introducing the Self-interest Principle (SiP) supposed to be in constant tension with, and as rational as, Grice’s Cooperative Principle. Politeness and self-presentational phenomena are subsumed under the operation of the SiP which embraces and coordinates the speaker’s own personal and interpersonal purposes.

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