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Low Tax Jurisdictions and Preferential Regimes : Policy Gaps in Developing Economies (Inglês)

This paper reviews recent international initiatives and domestic policy developments aimed at helping countries to protect their tax base against erosion by individuals and companies that allocate assets to or route income via low tax jurisdictions. The paper highlights the benefits and limitations of existing policy instruments from the perspective of capital-importing developing economies. Focusing on two common policy gaps for developing economies, options are explored for (i) introducing necessary charging provisions to ensure effective taxation of individuals, and (ii) an anti-diversion rule tailored to reflect developing economy contexts and administrative constraints. These proposals include a possible definition of excess profits in low tax jurisdictions and options for distribution keys to reallocate profits to countries where there is "real" economic substance and activity. The measures discussed could also address the diversion of profits to entities benefitting from preferential regimes in countries with high nominal tax rates.

Detalhes

  • Autor

    Leigh Pemberton,Jonathan, Loeprick,Jan

  • Data do documento

    2019/03/12

  • TIpo de documento

    Documento de trabalho sobre pesquisa de políticas

  • No. do relatório

    WPS8778

  • Nº do volume

    1

  • Total Volume(s)

    1

  • País

    Mundo,

  • Região

    Regiões Mundiais,

  • Data de divulgação

    2019/03/12

  • Disclosure Status

    Disclosed

  • Nome do documento

    Low Tax Jurisdictions and Preferential Regimes : Policy Gaps in Developing Economies

  • Palavras-chave

    transfer pricing; small and medium enterprise; corporate income tax system; exchange of information; Tax Evasion; tax avoidance; Tax Administration; transfer of asset; related party transactions; supply of good; internal revenue service; offshore financial center; domestic resource mobilization; corporation tax; access to information; corporate tax revenue; exempt from taxation; annual tax revenue; corporate tax base; effective tax rate; tax on income; large multinational corporation; income from taxation; corporate tax return; combination of factor; aggressive tax planner; categories of income; department of justice; double taxation agreement; nominal tax rate; corporate tax regime; foreign direct investor; foreign financial institution; ownership of asset; control of risk; corporate tax system; tax policy outcome; fight against corruption; offshore structure; offshore jurisdiction; foreign company; international tax; profit shift; offshore account; international standard; tax jurisdiction; connected party; low-tax jurisdiction; tax reduction; tax haven; automatic exchange; financial account; profit tax; civil code; legal structure; good policy; passive income; net worth; criminal activity; direct investment; banking secrecy; foreign subsidiary; beneficial owner; shell company; limited capacity; intellectual property; withholding tax; foreign tax; tax from october; back up; Tax Compliance; financial benefit; investment climate; financial crisis; tax liability; tax benefit; Real estate; excess profit; art market; gradual decline; income flow; tax crime; international cooperation; domestic law; international taxation; upfront payment; potential liability; risk allocate; ongoing innovation; development policy; international norm; open access; net importer; case law; alternative measure; client information; common policies; Investment strategies; trust deed; ownership structure; Tax Code; tax authority; legal arrangement; tax legislation; charitable purpose; international initiative; tax matter; allocation rule; excess return; minimum tax; foreign income; tangible asset; fundamental changes; negative effect; cash payment; international exchange; ancillary benefit; royalty payment; domestic charge; capital gain; enforcement efforts; interest deduction; individual income; administrative constraint; tax authorities; corporate profit; policy tool; administrative resource; domestic policies; parent company; internal governance; passive investment; information bias; money laundering; taxable dividend; foreign jurisdiction; full disclosure; press coverage; foreign investor; adverse consequence; administrative capacity; intangible asset; total tax; inheritance tax; foreign profit; corporate investment; corporate citizen; net effect; foreign parents; tax obligation; primary concern; wealth distribution; business structure; tax saving; tax planning; portfolio liability; taxable person; beneficial impact; Global Operations; corporate citizenship; anonymous reviewer; international community; investment asset; model legislation; explanatory material; long-term effect; global economy; tax payable; rebuttable presumption; original form; business practice; market force; effective approach; classification numbers; aggregate income; excess income; reporting obligation; foreign entity; transfer price; public attention; home country; fixed period; behavioral change; home countries; equity capital; address information; public discourse; functional analysis; global income; beneficial ownership; political influence; offshore center; bilateral exchanges

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