Expanding the amount of preferential royalty facilities with hard-to-recover oil reserves

The article deals with the economic attractiveness of hard-to-recover oil reserves in the Ural-Volga region development. The fuel and energy complex is a budgetforming one for oil-producing regions and contributes to the development of all sectors of the economy, and is bound by social responsibility. The current situation and trends in the global economy demonstrate that oil production intensification is a paramount task to all related industries efficiency improving, taxes being the main share in the cost structure. Therefore, in order to stimulate the reserves from low-permeability reservoirs development, tax exemptions are provided in the form of a reduced tax on mineral extraction. The paper considers an example of development efficiency improving due to tax incentives. According to the assessment results, the option with tax incentives is more beneficial for both the state and the subsoil user. Keywords: oil fields development; hard-to-recover reserves; taxation; qualified for tax relief; production intensification.

Refund of gminas' revenues lost due to statutory reductions in local taxes and charges

Currently, in Poland, there is a system of reimbursement of lost income, which is internally diversified. The legal institution of general subvention is used to some extent, as well as other ways of reimbursing lost income due to tax exemptions introduced by the legislator.

Tax incentives for R&D in the context of the development of fiscal space

The article deals with the main R&D expenditure based tax incentives such as tax credit and enhanced allowances in the context of the development of fiscal space due to their impact on innovative activities of loss-making, small and medium enterprises as well as startups. The author disclosed basic features of R&D expenditure based tax incentives in comparison with tax exemptions and accelerated depreciation. Cross-country comparisons in OECD revealed that it is often a case when SMEs and startups enjoy R&D tax credit and enhanced allowance with higher rates. In addition, they can also claim full reimbursement of unused tax benefits for R&D while large companies can only count on partial or even non-reimbursement of unused tax benefits and limited carry over period. Implied tax subsidy rates on R&D are analyzed through different OECD countries, as well as through enterprises different in size and profitability. In 2019 the largest R&D tax benefits were offered to profitable SMEs in France (ITSR was 43%) and Portugal (ITSR was 39%). The ITSR methodology is used to work out scenarios of introduction of R&D expenditure -based tax incentives in Ukraine. Calculation results are presented. The state of R&D tax incentives in Ukraine in the case of aircraft industry is analyzed. The introduction R&D expenditure -based tax incentives is argued as a replacement of tax exemptions which are currently used as a measure for R&D promotion in the aircraft industry in Ukraine in terms of improvement of R&D tax support efficiency and spur successful development of high value-added industries as an important prerequisite for the development of fiscal space in Ukraine.

On the economic impact of droughts in Central Europe. The decade from 1531 to 1540 from the Polish perspective

The period from around 1450 to 1550 in Europe is extremely interesting from the perspective of research on extreme weather events. It was a period of events that strongly influenced the societies and economies of the Old Continent. So far, the literature has been more focused on Western and Northern Europe, while as regards the region of Central Europe, the greatest attention was paid to the Czech Republic or Hungary. This article revolves around the Polish lands, which experienced their greatest economic boom in the 16th century. We consider whether and how the droughts of the decade from 1531 to 1540 might have affected the country’s economic development. We analyze a number of written sources which are the product of the treasury apparatus of the time (tax registers, data from water customs, tax exemptions, inventories of land estates etc.), but also information on fluctuations in product prices in the most important cities in this part of Europe. The work not only provides a detailed account of economic data, but also attempts to reflect on the relevance of linking information on fires in urban centres in the period characterized by weather extremes.

“The just judgements that Ḫammu-rāpi, a former king, rendered”: A New Royal Inscription in the Istanbul Archaeological Museums

This article publishes a royal inscription preserved on a clay tablet housed in the Istanbul Archaeological Museums. The inscription, which was intended for display on a stele, commemorates a royal grant of tax exemptions to nine Babylonian cities and presents the royal protagonist as a second Ḫammu-rāpi. The name and titulary of the king in question are not preserved, and the attribution of the inscription is accordingly uncertain. Following Jean-Vincent Scheil’s attribution of the text already in 1902, the study that accompanies an edition of the text argues that it should be attributed to Nabonidus, king of Babylon 556–539 BC, and explores its historical significance in this context.

Taxation of Insurance Premiums in the EU Cross-Border Insurance Business

As in many other cases of business activity, the performance of insurance activity involves various types of tax charges. Insurance contracts, having been excluded from the scope of value-added tax at the EU level, are subjected to taxes specific to insurance activity, namely insurance premium taxes, which are discussed in the article. However, insurance premium tax regulations are not harmonised at the EU level and vary immensely from one country to another. In fact, in some EU countries, including Poland, no such taxes have been implemented whatsoever. The issue discussed in the article is related to the fact that an increasing number of insurance companies perform insurance activity on a cross border basis. From this point of view, although there is no such tax in Poland, it may be of great importance to Polish insurance companies that insure risks located outside Poland. The regulations concerning the insurance premium tax depend on internal decisions of individual European Union countries, both in terms of the introduction of such tax, exemptions, and rates, and they may differ significantly across those jurisdictions. Due to the nature of cross-border activity and the rules on the localisation of the risk associated with the taxation of premiums, it was not clear whether and to what extent, in the case of insurance of risks located outside Poland, a tax obligation arises in respect of insurance premiums. These questions were addressed by the Court of Justice of the EU in several cases (C-118/96, C191/99, C-243-11). The CJEU decisions have revealed the multifaceted complexity inherent to the taxation of cross border insurance contracts.

Revenues from agricultural tax in the context of the principle of financial independence of municipalities

Motivation: The presented study addresses the important and current problem of agricultural tax and the resulting revenues in the context of financial independence of local government units. The scope of financial independence held by a municipality is significantly influenced by the right to exercise limited fiscal power. It means that the state provides municipalities with a number of powers to shape the local tax system, to set tax rates, to introduce individual tax exemptions, allowances and amortizations. Aim: The main purpose of the article is to present the importance of agricultural tax as the source of generating own revenues by municipalities in Poland, in the years 2015–2019, in the context of the principle of financial independence of municipalities. The supplementary purpose is to analyse and assess exercising the rights in terms of shaping revenues from agricultural tax in municipalities. Results: The analysis covers the level and share of revenues from agricultural tax in total revenues and municipal own revenues as well as the amount of revenues lost on its account. The conducted research has shown that agricultural tax plays the greatest role as the source of own revenues in managing the budgets of rural municipalities. However, it can be noticed that the fiscal function of the tax under study is increasingly smaller in each municipal category. It should be indicated that the structure of agricultural tax, which is basically unrelated to profitability and the volume of production in agriculture, in turn, translates into a low level of own revenues potential in municipalities. The system of taxing agriculture with agricultural tax, from the perspective of financial independence of municipalities, remains ineffective and the degree of independence presented by municipalities in this respect is far from a satisfactory level. The conducted analysis addressing correlations resulting from various types of reductions in agricultural tax against revenues from this tax showed that the scale of reductions, as the effect of using various tools by municipalities, was minimal and did not exceed 1% (which makes approx. 0.5%). The exception is the possibility of reducing the upper tax rates by a municipality.

THE ORETICAL AND LEGAL ASPECTS OF APPLICATION OF FINANCIAL GUARANTEES FOR TRANSIT FOREIGN ECONOMIC OPERATIONS

The article substantiates the need to use methods to ensure payment of customs duties, including financial guarantees. It is proved that financial guarantees are a method of ensuring the fulfillment of customs obligations in violation of the conditions for granting tax exemptions, including in the customs regime of «transit». The volumes of transit through the customs territory of Ukraine from the EU countries for 2014-2020 are analyzed. The essence and signs of transit foreign economic operations are determined. Cases are described in which transit will be considered as interrupted transit (hidden import). Statistical data are presented, which show that a significant share of transit operations are recognized by the customs authorities of Ukraine as interrupted transit. The volumes of provided financial guarantees are investigated. The tasks performed by ensuring the payment of customs duties through the use of financial guarantees under the customs regime of transit have been established. The types and forms of financial guarantees are determined depending on the method of movement of goods and commercial vehicles in the customs regime «transit» (transit, internal transit, joint transit, cabotage transit). The monetary pledge is described, as well as the guarantee document in written or electronic form. The peculiarities of the use of cash collateral are outlined. The order of registration of the documents provided at application of financial guarantees on transit foreign economic operations is opened. The conditions for providing financial guarantees by type (individual, multiple, general) are clarified. The cases in which the Customer is sent a request for payment of customs duties are described. There are formulas for calculating customs debt and penalties in case of non-payment of customs duties by the guarantor. The latest changes in the legal field that have a positiv

ANALISIS PERUBAHAN KETENTUAN SUBJEK PAJAK ORANG PRIBADI PADA UNDANG-UNDANG CIPTA KERJA TERHADAP PAJAK PENGHASILAN ORANG PRIBADI DAN MOBILITAS SUMBER DAYA MANUSIA

Reformasi pajak dalam Undang-Undang Cipta Kerja memuat ketentuan baru terkait subjek pajak orang pribadi yang cukup berbeda dengan Undang-Undang Pajak Penghasilan, seperti kriteria subjek pajak orang pribadi, pengecualian pajak beberapa penghasilan luar negeri, serta penerapan skema pajak khusus bagi warga negara asing yang telah menjadi subjek pajak dalam negeri. Ketentuan baru tersebut dapat berdampak pada basis pajak penghasilan, pergeseran sistem pajak menuju sistem teritorial, penyimpangan prinsip keadilan akibat perbedaan perlakuan pajak, serta mobilitas sumber daya manusia akibat keringanan pajak yang ditawarkan dalam skema pajak khusus. Penelitian ini menganalisis potensi dampak tersebut menggunakan metode kepustakaan dengan teknik dokumentasi. Faktanya, Undang-Undang Cipta Kerja tidak mengubah narasi Pasal 4 Ayat (1) Undang-Undang Pajak Penghasilan sehingga sistem pajak Indonesia masih memiliki kecenderungan terhadap sistem worldwide. Keringanan pajak dalam skema pajak khusus juga tidak berpengaruh signifikan terhadap mobilitas sumber daya manusia, terutama tenaga kerja asing, karena respon mobilitas tidak hanya bergantung pada kebijakan pajak. Kemudian, pengecualian pajak beberapa penghasilan luar negeri dan penerapan skema pajak khusus juga tidak dilakukan secara cuma-cuma, melainkan diiringi syarat untuk menempatkan investasi di Indonesia dan melakukan alih pengetahuan. Dengan demikian, potensi penurunan basis pajak dan penyimpangan prinsip keadilan harus disikapi dengan bijaksana dan berorientasi pada prospek manfaat di masa mendatang. Job Creation Act contains new provisions related to individual tax subjects that are quite different from the Income Tax Law. Those provisions include criteria for individual tax subjects, tax exemptions for some foreign incomes, and the application of special tax schemes. Those provisions can affect the income tax base, shifting the tax system into a territorial system, create injustice issues from different tax treatments, and transform the mobility of human resources due to tax facilities in special tax schemes. This study analyzes those potential impacts using the library method. Stated that the Job Creation Law does not change the sentence of Article 4 Paragraph (1) of the Income Tax Law so that Indonesia still tends a worldwide system. The special tax schemes do not have a significant effect on the mobility of human resources because the mobility response not only depends on tax policies but also on other factors. Then, the new tax exemptions and the special tax schemes are not applied for free but accompanied by conditions to invest in Indonesia and transfer knowledge. Thus, the potential reduction in the tax base and tax injustice issues must be addressed wisely and oriented to the prospect of future benefits.