TAXING CORPORATE INCOME by A公司收入的征税.pptVIP

TAXING CORPORATE INCOME Review of paper and Comments by Jack Mintz Main Points of Paper Meade report considered three forms of rent taxes on corporations - R, R+F and S bases Authors focus on two main issues How economies have changed since 1978 affecting corporate tax policy (source vs residence base taxation) Examine different tax systems with emphasis on “what to be taxed” and “where to tax it” Background UK corporate tax system generally move to income base with lower rates and broader bases since 1978 ECJ cases affected ACT, treatment of outbound and inbound investment Around world -- today compared to 30 years ago falling general statutory tax rates (48% to 28%) CIT revenues have been buoyant as a share of GDP across OECD countries falling importance of manufacturing and rising importance of services, some tradable like financial (and business services). (greater use of profit-insensitive taxes on businesses) WHAT HAS CHANGED Globalization of economic activity Tax competition -- for capital or profits? statutory rates -- income shifting and acquire rents Financial innovations and debt vs equity distinction Relationship of PIT and CIT residence of owners vs residence of corporation influence of PIT on investment Organizational form -- choice at small business level (but also within corporate groups) Role of Corporate Tax Backstop to personal tax (withholding for residence tax) Taxing foreign income (source -- crediting) Rent tax (source role) (Surrogate benefit tax-- source role) Alternative Tax Bases Source-based Tax on return to equity (problems of attribution to jurisdiction) formula apportionment Corporate flow of funds (R, R+F, S bases) Allowance for corporate equity (Croatia, Belgium) Comprehensive Business Income Tax Dual Income taxes (schedular, lower tax on capital income, CIT) Business value taxes (Michigan, Italy, Hungary) Residence-based Shareholder tax on accrued worldwide profit (problem of tracking) Residence-base corporate tax