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base erosion Archive

Impact of National Tax Reforms on the EU Economy

TweetShareSharePin0 Shares Note: The following is the testimony of Daniel Bunn, Tax Foundation Vice President of Global Projects, prepared for a EU Parliament Subcommittee on Tax Matters hearing on October 11, 2021, regarding the impact of national tax reforms on the EU economy. Thank you for the opportunity to testify today. My name is Daniel Bunn, and I am

Patent Box Regimes in Europe, 2021

TweetShareSharePin0 Shares Patent box regimes (also referred to as intellectual property, or IP, regimes) provide lower effective tax rates on income derived from IP. Most commonly, eligible types of IP are patents and software copyrights. Depending on the patent box regime, income derived from IP can include royalties, licensing fees, gains on the sale of

Comments on the Wyden, Brown, Warner International Tax Overhaul Draft

TweetShareSharePin0 Shares Introduction Tax Foundation welcomes the opportunity to offer comments on the Wyden, Warner, Brown discussion draft on international taxation. Tax Foundation is a nonprofit think tank based in Washington, D.C., and our mission is to improve lives through tax policies that lead to greater economic growth and opportunity. We use the four principles

A Hidden Tax on Domestic Activities & Foreign Profits

TweetShareSharePin11 Shares The U.S. corporate tax code is a complicated behemoth, loaded with numerous arcane provisions—some of these providing special tax breaks, others imposing special tax penalties. Among the latter group, indirect expense allocation rules penalize domestic activities and impose a hidden surtax on foreign profits. While arcane, expense allocation rules are relevant to current

U.S. Global Minimum Tax Revenue Analysis

TweetShareSharePin0 Shares The Biden administration has proposed significant changes to the tax rules that govern how much U.S. companies owe on their foreign profits while working to negotiate a global minimum tax. However, the global minimum tax and the Biden administration’s proposals are quite different. A recent Tax Foundation report dug into the details on

Global Foreign Direct Investment | UN World Investment Report

TweetShareSharePin0 Shares The United Nations (UN) recently released its annual “World Investment Report,” which shows the dramatic fall in global foreign direct investment (FDI) caused by the COVID-19 crisis. A partial recovery is expected for 2021, with the most optimistic scenario showing a return to 2019 FDI levels by 2022. However, uncertainty remains high, with

Anti-Base Erosion Provisions and Territorial Tax Systems in OECD

TweetShareSharePin0 Shares Key Findings All OECD countries with territorial tax systems have designed provisions that seek to prevent base erosion and profit shifting by multinational corporations. Designing a territorial tax system requires balancing competing goals: exempting foreign business activity from domestic taxation, protecting the domestic corporate tax base, and creating a simple system. A system

Reviewing the Academic Literature on Profit Shifting

TweetShareSharePin0 Shares Note: This is a preview of the full article originally published by Tax Notes. To read the full article, click the download links above. Brief Summary In recent years, significant unilateral and global efforts have been made to address the issue of profit shifting. However, reviewing the academic literature on profit shifting, one finds

A Global Minimum Tax and Cross-Border Investment: Risks & Solutions

TweetShareSharePin0 Shares   Launch U.S. International Tax Reform Resource Center Key Findings The political effort to address profit shifting and limit the benefits of using low-tax jurisdictions to facilitate cross-border investment has focused on adopting a global minimum tax applicable to large multinational corporations. While a global minimum tax could act as a backstop to
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