scholarly journals Optimal Policies Against Profit Shifting: The Role of Controlled-Foreign-Company Rules

2016 ◽  
Author(s):  
Andreas Haufler ◽  
Mohammed Mardan ◽  
Dirk Schindler
Keyword(s):  
Foreign Company ◽  
Profit Shifting ◽  
Optimal Policies

scholarly journals Introducing POSVAR: A dataset on refugee-related violence

2018 ◽  
Vol 56 (1) ◽  
pp. 134-145 ◽  
Author(s):  
Christian Gineste ◽  
Burcu Savun
Keyword(s):  
Time Series Data ◽  
Physical Violence ◽  
Series Data ◽  
The Political ◽  
Optimal Policies ◽  
Different Types ◽  
Societal Violence ◽  
Over Time ◽  
Cross National

While scholars have for some time debated the role of refugee flows in the international spread of conflict, most evidence has been indirect due to the scarcity of systematic data on refugee-related violence. The Political and Societal Violence By And Against Refugees (POSVAR) dataset addresses this lacuna by providing cross-national, time-series data on refugees’ involvement in acts of physical violence in their host state, either as the victims or the perpetrators of violence, individually or collectively, in all countries between 1996 and 2015. In this article, we provide an overview of the main features of the dataset, identify its limitations, and trace variation in reported levels of refugee-related violence over time and across different types of actors. We emphasize that the data may be helpful to both researchers and policymakers for more accurate understanding of the prevalence of refugee-related violence and the design of more optimal policies to mitigate it.

ANALISIS PENERAPAN CONTROLLED FOREIGN COMPANY RULES DALAM MENGATASI BASE EROSION AND PROFIT SHIFTING DI INDONESIA

INFO ARTHA ◽  
2017 ◽  
Vol 3 ◽  
pp. 1-14
Author(s):  
Alfa Mightyn ◽  
Arifah Fibri Andriani
Keyword(s):  
Action Plan ◽  
Tax Avoidance ◽  
Building Blocks ◽  
The Other ◽  
Foreign Company ◽  
Tax Revenue ◽  
Profit Shifting ◽  
The World ◽  
Domestic Law ◽  
Cfc Rules

One cause for the inability to achieve the expected tax revenue target for some last years was the practice of tax avoidance. One form of tax avoidance is the utilization of Controlled Foreign Company (CFC) to defer the recognition of income from overseas over WPDN capital to be taxed in the country. This practice is also faced by many other countries in the world. The issue of the Base Erosion and Profit Shifting (BEPS) has been of concern to developed and developing countries. G20 countries cooperate with OECD to form a BEPS Project to formulate measures to address these BEPS. Indonesia as one of the Associate Members of the Project BEPS has a position that is parallel to the other OECD countries and participates in implementing the BEPS results. BEPS Project has resulted in BEPS Action Plans which one of them is Action 3: Strengthening CFC Rules. Action 3 will provide recommendations to the domestic law related to the design of CFC Rules. Until now, related to Action 3, BEPS Project has issued a Public Discussion Draft Action 3: Strengthening CFC Rules. This draft is divided into seven "building blocks" required for CFC Rules to be effective. The aim of this study is to analyze the effectiveness of CFC Rules in Indonesia, whether it is sufficient to prevent BEPS. After that, we can determine what steps should be taken by Indonesian tax authorities to strengthen the CFC Rules in Indonesia based on seven dimensions of building blocks. The conclusions of this study are (1) CFC Rules in Indonesia as a whole have not been able to overcome BEPS; and (2) When compared with the recommendations of the Discussion Draft Action Plan 3, CFC Rules Indonesia needs to be improved. However, the necessary improvements should be adjusted to match the needs and characteristics of Indonesia. 

scholarly journals Amendment of India Mauritius DTAA and its Impact on Foreign Investment in India

2019 ◽  
Vol 8 (2S3) ◽  
pp. 1447-1454
Keyword(s):  
Foreign Investment ◽  
Foreign Capital ◽  
Capital Gains ◽  
International Taxation ◽  
Small Island ◽  
Profit Shifting ◽  
Full Effect ◽  
To Come ◽  
The Impact

The objective of this paper is to the study the impact of the amendment of India Mauritius DTAA on foreign investment in India. It provides adetailed analysis of how Mauritius, a small island country became the most favourite route for foreign investor in India during the period 2000 to 2017. The paper identifies the reasons for emergence of Mauritius as the foremost exporter of foreign capital to India and in this context examines the role of the Agreement on Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes of Income and Capital Gains between India and Mauritius (DTAC). In 2016, DTAC was amended and with the implementation of General Anti Avoidance Rule (GARR) from 2017 by India and changes in international taxation zeitgeist due to OECD project on Base Erosion Profit Shifting (BEPS) the Mauritius route faced new challenges. The paper studies the influence of these changes on FPI and FDI investments flow from Mauritius to India.It finds that advantage of Mauritius in FDI and FPI flow has come down in 2018-19 and its share in foreign investment is likely to come down further with the amendment of the DTAC taking full effect from April 2019. However,amendment has given Mauritius a competitive advantage in channelizing debt investment to India as compared to its competitors like Singapore and the Netherlands and in future we may see higher debt investment from Mauritius.

scholarly journals Big Data: From modern fears to enlightened and vigilant embrace of new beginnings

2020 ◽  
Vol 7 (2) ◽  
pp. 205395172093670
Author(s):  
Nicole Dewandre
Keyword(s):  
Artificial Intelligence ◽  
Big Data ◽  
Black Box ◽  
Optimal Policies ◽  
Three Stages ◽  
Asymmetrical Power ◽  
New Beginnings ◽  
The One

In The Black Box Society, Frank Pasquale develops a critique of asymmetrical power: corporations’ secrecy is highly valued by legal orders, but persons’ privacy is continually invaded by these corporations. This response proceeds in three stages. I first highlight important contributions of The Black Box Society to our understanding of political and legal relationships between persons and corporations. I then critique a key metaphor in the book (the one-way mirror, Pasquale’s image of asymmetrical surveillance), and the role of transparency and ‘watchdogging’ in its primary policy prescriptions. I then propose ‘relational selfhood’ as an important new way of theorizing interdependence in an era of artificial intelligence and Big Data, and promoting optimal policies in these spheres.

scholarly journals THE CONTEMPORARY INTERNATIONAL TAX SYSTEM, DEVELOPING COUNTRIES, BEPS AND OTHER CURRENT ISSUES / O SISTEMA TRIBUTÁRIO INTERNACIONAL CONTEMPORÂNEO, PAÍSES EM DESENVOLVIMENTO, BEPS E OUTRAS QUESTÕES ATUAIS

2018 ◽  
Vol 6 (7) ◽  
Author(s):  
Marcos Aurelio Pereira Valadão
Keyword(s):  
Developing Countries ◽  
International Organizations ◽  
The South ◽  
Profit Shifting ◽  
Tax System ◽  
Tax Systems ◽  
International Tax ◽  
Rich Countries

This paper analyzes the Contemporary International Tax System with focus on international tax cooperation, the participants of this context, that goes beyond the countries, and the issues that are present in base erosion and profit shifting (BEPS) Project with the focus on  those that are the most important for developing countries, also taking into consideration the Brazilian approach to those issues. It also verifies the role of international organizations (including NGOs), The paper consider other aspects, for example, the south Centre initiative on tax cooperation, and the biased approach from the northern rich countries towards the south poorer economies, coming to the conclusion that the differences between the needs of of developed and developing countries, which affect their tax systems, and the different tax systems itself, must be taken into account.

The role of headquarters in multinational profit shifting strategies

2013 ◽  
Vol 21 (2) ◽  
pp. 248-271 ◽  
Author(s):  
Matthias Dischinger ◽  
Bodo Knoll ◽  
Nadine Riedel
Keyword(s):  
Profit Shifting

Investment Arbitration in the Energy Sector

2020 ◽  
pp. 814-842
Author(s):  
Elena Cima
Keyword(s):  
Dispute Settlement ◽  
Energy Sector ◽  
Foreign Company ◽  
Foreign Investor ◽  
Energy Investment ◽  
Foreign Investors ◽  
Significant Percentage ◽  
Investment Arbitration ◽  
The World

This chapter studies the role of investment arbitration in the energy sector, which has received increasing attention over the last decade. International energy investment accounts for a significant percentage of all global investments and makes up the largest portfolio of international arbitrations in the world today. Energy-related disputes can take many forms. They may occur between two states, two private parties, or a private party and a state—in which case they may relate either to an investment by a foreign company in a state or to a commercial contract between a foreign company and a state. The chapter considers only one type of energy-related dispute, namely investment disputes between a foreign investor and a state. It particularly focuses on arbitration, which represents ‘the most widely used form of dispute settlement between foreign investors and host States’.

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