Browse by: "PRE-2003"
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This Agreement contains two models for bilateral agreements drawn up in the light of the commitments undertaken by the OECD and the committed jurisdictions. The Working Group was chaired by Malta and the Netherlands and marks the first results of the OECD's collaboration with the jurisdictions that have committed to improve transparency and establish effective exchange of information in tax matters.
Currently, there is a lack of consensus amongst OECD Member countries as to how profits should be attributed to a permanent establishment (PE). As a first step in remedying this situation a working hypothesis has been developed as to the preferred approach for attributing profits to the PE. The basis for the working hypothesis is to examine how far the approach of treating the PE as a hypothetical distinct and separate enterprise can be taken and how the guidance in the OECD Transfer Pricing Guidelines could be applied, by analogy, to attribute profits to a PE. This discussion draft contains the results of testing the working hypothesis in general (Part I) and to PEs of banks (Part II). Public comments are invited in order to assist in the development of an OECD consensus on the attribution of profits to a PE.
Prepared against this background, the OECD report Behind the Corporate Veil: Using Corporate Entities for Illicit Purposes opens ways to prevent and combat the misuse of corporate entities. The report shows that the types of corporate entities misused most frequently are those that provide the greatest degree of anonymity to their beneficial owners. With that in mind, the report offers governments and other relevant authorities a menu of policy options for obtaining information on the beneficial ownership and control of corporate entities in order to combat their misuse for illicit purposes.
Unemployment and related welfare benefits help prevent those without work from falling into poverty but at the same time reduce the incentive to work; this is one of the main dilemmas of social policy. For the first time, this publication analyses the complicated interactions of tax and benefit systems for many different family types and labour market situations. This volume enables the reader to discover exactly what features of the tax and benefit system cause disincentives to work; it compares all the different benefits made available to those without work and the taxes they pay with potential in-work incomes. In-work incomes in some countries are little higher than benefits made available to those without work. Furthermore, some benefits are withdrawn as earnings rise, reducing the attraction of moving up the job ladder. Unemployed families who face these disincentives may become locked in unemployment and are at risk of exclusion from the labour market.
Unemployment and related benefits help prevent those without work from falling into poverty but at the same time reduce the incentive to work; this is one of the main dilemmas of social policy. The Benefit Systems and Work Incentives series, started in 1998, addresses all the complicated interactions of tax and benefit systems for many different family types and labour market situations. This year's edition includes a section that describes the changes that occurred over the two-year period 1995-1997 affecting benefit systems and work incentives in OECD countries. We have also included some detailed calculations which illustrate the uses of net income calculations and the resulting marginal effective tax rates. Furthermore, Greece has now been included amongst the countries in our study. The series is a valuable tool used to compare the different benefits made available to those without work (net of taxes) with potential in-work incomes. This differential, in some countries, is very small. Furthermore, the reduction of certain benefits, as earnings rise, sometimes reduces the attraction of moving up the job ladder. Consequently unemployed families, who face these disincentives, may become locked in unemployment and are at risk of exclusion from the labour market.
Unemployment and related welfare benefits help prevent those without work from falling into poverty but at the same time, reduce the incentive to work; this is one of the main dilemmas of social policy. This annual report presents a description of all the benefits available to those without work, and of the taxes they pay, and presents a set of tables facilitating cross-country comparisons of tax-benefit systems. It compares the incomes of a range of families in and out of work in 1999 and describes the incentives to work, either part-time or full-time, across OECD countries.
This publication provides information about VAT and excise duty rates (for alcoholic beverages, mineral oil products and tobacco products) across the OECD. It also describes a range of taxation provisions in OECD countries such as the taxation of motor vehicles and outlines the preliminary findings of a study of taxes on environmentally relevant goods currently in progress.
This publication provides information about VAT/GST, excise and environmental taxes in OECD Member countries. It also provides information about indirect tax topics currently under study at the OECD. It describes a range of taxation provisions such as the taxation of motor vehicles and also outlines the preliminary findings from discussions on taxation of electronic commerce currently in progress.
This report examines the currently highly topical issue of corporate tax incentives for foreign direct investment (FDI). The ability to offer an internationally competitive tax system is increasingly seen today as a determinative factor influencing FDI. With corporate income tax identified as the component that impacts most directly on multinational companies, much of the pressure for lowering host country tax burdens to attract capital is focused upon this tax. At the same time, corporate taxation plays an important withholding function, raising revenues on domestic-source income that might otherwise escape the tax net. The desire to tax this income while not discouraging foreign investors raises critical questions concerning the sensitivity of FDI to taxation and the appropriate setting of various tax provisions that determine the host country tax burden and influence investment and financing behaviour.
This report considers various corporate tax measures to encourage FDI and a range of issues relevant to assessing their use. Given the central question of how much additional investment can be expected from tax relief and at what cost, the report summarises recent empirical findings which show increasing sensitivity of FDI to host country tax burdens, consistent with trends towards increasing globalisation of production. Other findings are considered which highlight tax-planning opportunities created by certain approaches, leading to unintended revenue leakage. The report emphasises the need to assess possible host and home country tax interactions which can influence tax incentive results, and more generally the need to look beyond what conventional economic analysis might suggest.
While the report is intended primarily as a guide for policy makers in emerging market economies, it may serve as a reference document to tax policy analysts more generally
This 1963 report presents the articles on the avoidance of double taxation on income and capital, as agreed upon by the Fiscal Committee. Double taxation is the taxation of a single taxpayer with respect to the same subject matter over the same period in more than one country. This draft aims to inspire further conventions on the elimination of double taxation, a threat to trade and migration. The report includes commentaries on the articles, progress on the elimination of double taxation, and possible future developments.
How do taxes and charges for transport in, for example, France compare with those in Germany? Do hauliers in one country pay more than in the other, and what impact does this have on the profitability of haulage in each country? Is the impact of an increase in tax on diesel the same in each country or are differences in the taxation of labour more significant? Do these differences distort the international haulage market? This book provides a framework for international comparisons and discusses the economic principles for efficient systems of taxation. The work provides a basis for addressing the questions "what is the right level for transport taxes" and "what kinds of charges should be used".
Environmental taxes are receiving growing interest world-wide. From an environmental perspective, a key driver has been the search for more efficient and cost-effective approaches for implementing domestic environmental policies. From a fiscal policy perspective, growing pressures have been exerted to reduce income tax rates and to offset this by broadening the tax base. These reforms provide opportunities to introduce new environmental taxes in a revenue-neutral manner and simultaneously to achieve environmental and fiscal policy objectives.
This volume presents recent developments in designing and implementing environmental taxes in China and OECD countries. Key challenges and opportunities are highlighted, including the role of removing or reforming existing distortionary subsidies that are damaging to the environment; restructuring existing taxes; and introducing new environmental taxes. The papers, which were presented at an OECD Workshop held in October 1998, provide the reader with a unique comparative analysis.
It is now widely recognised that a greater use of market based instruments is a key element of effective and economically efficient environmental policies, and an important framework condition for sustainable development. Hence, over the last decade, economic instruments have been playing a growing role in environmental policies of OECD countries. In this context, a distinctive feature is the increasing role of environmentally related taxes. All countries have introduced environmental taxes to a varying extent, and an increasing number of countries are implementing comprehensive green-tax reforms, while others are contemplating doing so.
This report analyses current use of environmentally related taxes in OECD Member countries. Focus is given to their environmental effectiveness. The report identifies obstacles to a broader use of such taxes -- in particular the fear of loss of sectoral competitiveness -- and ways to overcome such problems.
This collection of experiences of fiscal decentralisation across a wide range of OECD-Member and non-member economies reveals lessons which are equally of relevance to both groups of countries. A major finding is that fiscal decentralisation is often confused in the latter group of countries with the removal of central-government control over subnational finances. This is a mistake; it may lead to fiscal irresponsibility on the part of local authorities, deteriorating fiscal positions at both levels, and high costs due to duplication of fiscal institutions. The book also finds that insufficient attention has been given to local revenue generation, as opposed to intergovernmental transfers.
The issue of fiscal decentralisation in emerging economies is particularly important, because it arises, in part, from a desire to enhance democracy and local accountability. However, the devolution of responsibilities must take place in an atmosphere of transparency, where the local expertise exists to manage budgeting. Serious consideration must be given to revenue sourcing and effective expenditure control. Finally, local spending must match available revenues without becoming an additional strain on central government resources.
The relationship between different levels of government is one that is continually under review. Policy-makers ensure the expenditure and revenue functions of each tier of government with a view to balancing efficiency, equity and democratic considerations. Over the last decade, the tendency in a number of countries has been to decentralise both expenditure and revenue functions to lower levels of government. Greater autonomy in raising revenues has been given to intermediate and local levels of government.
Setting up of local fiscal systems and intergovernmental financial relations involves multiple and often conflicting economic and political objectives. Practically, it is one of the most complex reform processes in the area of public finance and one that is permanently on the political agenda of both OECD countries and economies in transition. Yet there is no international, comparative set of information available to support this process. The international comparable statistics on revenue of local autonomy and the design of national fiscal control are either lacking or insufficient.
This study summarises the overall substantial and methodological framework of a project on fiscal design, which has been carried with the OECD. The results and comparative findings of the OECD Fiscal Design surveys are reported too. The surveys took place in six countries in Central and Eastern Europe: three OECD Member countries, the Czech Republic, Hungary and Poland, and the three Baltic States, Estonia, Latvia and Lithuania.
Globalisation has had positive effects on the development of tax systems and has encouraged countries to engage in base broadening and rate reducing tax reforms. However, it has also created an environment in which tax havens thrive and in which governments may be induced to adopt harmful preferential tax regimes to attract mobile activities. Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases, such as labor and consumption, thus adversely affecting employment and undermining the fairness of tax structures.
The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices. To achieve this, OECD Member governments have developed "Guidelines on Harmful Preferential Tax Regimes". These Guidelines will discourage the spread of harmful preferential tax regimes and encourage countries with such regimes to eliminate them. To counteract both tax havens and harmful preferential tax regimes, Member governments have also agreed to pursue vigorously the implementation of the other Recommendations in the Report, including entering into a dialogue with non-member countries.
The first report outlines the reasons why international tax avoidance and evasion through the use of tax havens is a concern to the tax authorities of OECD Member countries and examines measures introduced to combat such use. The second report sets out the problems posed for tax administrations by the fact that their resident taxpayers make use of base companies (generally subsidiary companies) in tax havens to shelter there income derived from source countries (which may in some cases be the residence country itself) and in that way to escape tax normally payable to the country of residence. The third report deals with the problems created for tax authorities in source countries by the mechanism of "treaty shopping". The final report deals with taxation and the abuse of bank secrecy.
The taxation of professional services and other activities of an independent character under Article 14 of the OECD Model Tax Convention is problematic. For example, what activities and entities fall within Article 14 as opposed to the business profits Article (Article 7)? Is the distinction between those activities and entities satisfactory and easy to apply? What are the practical differences between taxation under Article 7 and 14? This report analyses those questions in detail and concludes that there is no practical difference between the two Articles or if any differences did in fact exist, there is no valid policy justification for them. It recommends that Article 14 be eliminated from the Model and describes the changes that would need to be made to the Articles and Commentary of the Model as a consequence.