While significant progress has been made in international tax cooperation, the interests of developing economies require greater priority and attention.
... See More + This paper considers policy options that are currently under consideration in different international fora, drawing on the WBG's work in supporting tax policy and administration reforms in developing economies. The overall direction of the reform debate is promising and could shift taxing rights towards market jurisdictions, as well as strengthen the tools available to deter profit shifting to low-taxed entities. Some of the proposals under discussion could be adopted in the near-term but need to be better tailored to developing economy needs. This paper identifies five areas for improvement. First, the proposals relating to the allocation of global non-routine profits need to be simplified and incorporate more formulaic approaches. Second, work on the allocation of taxing rights should include in its scope the option to reallocate all non-routine profit, rather than only that part reflecting user value or marketing intangibles. Third, the (income inclusion) idea of targeting lowly taxed profits is sound, but it needs to be a tool for both capital importing and exporting countries. Fourth, detailed guidance is needed on the use of withholding tax as an efficient collection mechanism for source jurisdictions and on the application of mandatory safe harbors with an arm’s length let out. These tools can help ensure efficient administration in developing economies. And, fifth, effective administration requires appropriate access to information. Practical limitations to accessing relevant information for developing economies need to be removed. This should include an amendment to current standards allowing jurisdictions to impose robust domestic filing obligations for CBCR (and/or similar future additional reporting obligations).
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Working Paper (Numbered Series) 142256 OCT 01, 2019
In this context, Bhutan can become wealthier through accelerating both domestic and foreign investment, as well as signing investment treaties.
... See More + These investments could provide not just capital but also bring necessary skills, knowledge and ideas, and help the country move beyond hydropower. Today FDI inflows are small and constrained, on the one hand, by regulatory barriers and insufficient investment promotion, and, on the other, by inadequacies in skills and infrastructure. Bhutan can benefit from the experience of East Asia and other countries on how to break out of this low investment trap. FDI can help the macroeconomic balance by increasing exports and reducing the current account deficit, although it is not clear the future impact on growth, since it will depend on the quality and type of FDI inflows. FDI can also help create trade. Theoretically, firms invest abroad to expand their sales markets when trade costs are too high, therefore FDI is a substitute for trade. FDI in non-tradable sectors (services, etc) has this feature. However, in practice, FDI goes to export-oriented sectors including extractives but also manufacturing. Given the landlocked nature of geographic setting of Bhutan (with higher trade cost than countries such as India or Bangladesh), FDI could go primarily to non-tradable (at least as shown in the recent trend in the greenfield FDI). In this context, it will be important to use FDI to tap into regional value chains.
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Pensions and broader forms of retirement income do not stop at national borders. As part of globalization, individuals increasingly spend part of their working or retirement life abroad but want to keep or move their acquired rights, accumulated retirement assets, or benefits in payment freely across borders.
... See More + This raises the issue of the portability and taxation of cross-border pensions in accumulation and disbursement. This paper addresses both portability and taxation issues from the angle of which type of pension scheme defined benefits (DB) or defined contributions (DC) is more aligned with globalization in establishing individual fairness, fiscal fairness, and bureaucratic efficiency. The paper shows that DC schemes tend to dominate DB schemes both at the level of portability and taxation.
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Working Paper (Numbered Series) 136559 APR 01, 2019
This paper examines the level of investment protection for selected countries along the Belt &Road Initiative (BRI), based on coding the textual content of 17 investment laws and 648international investment agreements (IIAs).
... See More + We find substantial heterogeneity in the levels ofprotection provided in the reviewed laws and IIAs, and consequently along the same BRI corridorsand projects. Moreover, the current lack of effective enforcement – as shown by past treatyviolations and lack of efficient domestic court systems – poses an additional layer of risk forinvestors. Substantive improvements and harmonization in standards of treatment and recoursemechanisms in these legal instruments can help reduce investment risks. Given the scale of plannedinvestments, to minimize dispute risks, BRI governments will need to ensure full understandingof their law and treaty commitments and strengthen the capacity to enforce them.
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Working Paper (Numbered Series) 134017 JAN 24, 2019
Domestic Violence (DV) is a universal phenomenon that affects millions of women of all social strata worldwide. It is the most pervasive, common, under-recognized, underestimated and under-reported type of violence against women.
... See More + It reflects discriminatory social norms, stereotypes, impunity and gender inequality. It is all too often considered as a “private, family issue”, widely accepted and minimized although it impairs the full enjoyment of life and fundamental rights and freedoms by victims and survivors who are overwhelmingly women. Domestic Violence (DV) is a development challenge and has a high economic and social cost, including health and medical costs, death, suicide, depression, lost productivity, lost income, , psychological consequences and trauma, increased stress, reactive violence, reduced ability to study or find and hold a job, judicial and prison costs, economic insecurity and abuse, debt, housing instability, homelessness, inter alia1. Beyond data and statistics, DV undermines autonomy and represents an enormous loss in terms of wellbeing not only for the women affected but also for the men who share their lives, for their children, their families and their societies. The Compendium on International and National Legal Frameworks on Domestic Violence (the “Compendium”) provides a survey of the key international and regional instruments as well as national legislation as they relate to domestic violence.
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This paper investigates the costs and benefits of concluding double tax treaties with investment hubs. Based on a sample of 41 African economies from 1985–2015, the results suggest that signing treaties with investment hubs is not associated with additional investments; yet, these treaties tend to come with nonnegligible revenue losses.
... See More + Building on a theoretical model, the paper investigates the role of treaty shopping in driving nominal investment flows and provides indirect evidence for its importance in the sample.
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Policy Research Working Paper WPS8623 OCT 25, 2018
The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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The Europe and Central Asia (ECA) region has a rich history of regional integration and connectivity to the broader world economy, which has stimulated the growth of knowledge and technological innovation.
... See More + Indeed, through migration, trade, investments, and other interactions, ECA countries have depended on, and benefited from, connectivity with other countries for centuries. A key insight of this report is that ECA’s international connectivity through trade, foreign direct investment, migration, telecommunications, transportation, and other avenues facilitates the transfers of knowledge and technology that are critical to long-term growth and shared prosperity. These connections complement one another because of the tacit (learning by doing), rather than explicit (contained in books or blueprints), nature of knowledge transfers. Migration, for example, enhances knowledge spillovers through trade and foreign investment by migrants transferring information on foreign markets and supporting connections to them. Similarly, the internet and efficient transport links are both necessary for successful e-commerce. This short publication summarizes the main findings of the World Bank flagship study Critical Connections. Critical Connections was born out of the desire to help policy makers focustheir attention on their long-term goals of regional and global integration to capture the benefits of connectivity, from which ECA countries had advanced so far during the early years of market expansion in the 1990s and early 2000s. Its primary purpose is to offer a deep analysis of ECA connectivity and how it has evolved over the past two decades. In a key innovation of the study, a network analysis measure of multidimensional connectivity captures the relationship between different forms of connectivity and their joint impacts on growth and the transmission of shocks.
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The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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The aim of this report and toolkit is to provide analysis of and options for the tax treatment of OITs. To these ends, it addresses several questions: (i) What considerations arise in deciding whether or not such transfers should be taxed in the country in which the underlying asset is located?
... See More + (ii) To which types of assets do these considerations suggest that any such taxation should apply? (iii) How can such taxation, if adopted, best be designed and implemented as a practical, legal matter? This report and toolkit does not purport to provide binding rules or authoritative provisions of any kind nor does it aim to establish an international policy standard of any kind. Rather, it is intended to describe an international taxation issue of particular concern to developing countries, and to provide practicable guidance to them on options for how to address that issue, should they choose to do so. As such, the report represents the analysis and conclusions of the tax staffs of the four partner organizations, and does not represent the official views of the organizations’ member countries or Management.
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