The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant ref...The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.展开更多
The phenomenon of global fragmented production and associated trade in intermediate products,including intangible assets,has changed how economists study globalization and how new public policies are shaped.Understand...The phenomenon of global fragmented production and associated trade in intermediate products,including intangible assets,has changed how economists study globalization and how new public policies are shaped.Understanding cross-border flows of disembodied knowledge,often associated with intellectual property(IP),is essential for analyzing how modern economies operate.Available data to document these international IP-related knowledge flowsdnamely cross-border payments for IPdare distorted by various factors.Tax planning by multinational enterprises has seriously distorted the measurement of cross-border IP flows,affecting national measurements of imports,exports,GDP,and productivity.The tax-induced mismeasurement could be more than 35% of global charges for use of intellectual property,and greater for individual countries,particularly high-taxrate countries.International initiatives to address the effects of tax base erosion,profit shifting,and other statistical initiatives on global value chains will improve future measurements of cross-border IP flows,improving the understanding of both the creation and uses of IP.展开更多
Today,international taxation is at an inflection point.The implementation of action plan on base erosion and profit shifing(BEPS)and enforcement of the Belt and Road Initiative are reshaping taxation rules and princip...Today,international taxation is at an inflection point.The implementation of action plan on base erosion and profit shifing(BEPS)and enforcement of the Belt and Road Initiative are reshaping taxation rules and principles.As a crucial aspect of outbound taxation,foreign tax credit is expected to embrace the normative objectives of the new era,which emphasize the importance of subjecting all trans-border business activities to equitable,efficient,and coordinated taxation.Currently,China's foreign tax credit prescribes in an incompatible pattern;it lacks clear legislative intent,despite marking specific rules with archaic unilateral characters.To reform this regime,legislative principle should reflect the latest consensus on the economic activities'nexus and ensure that the income derived from trans-border transactions falls under a minimum tax.Regarding specific rules,it is strongly suggested that active and passive incomes be distinguished and the equity holding threshold of obtaining indirect credit be lowered.China's foreign tax credit reform should take an inclusive perspective,actively participating in the cooperation between countries.展开更多
文摘The Organisation for Economic Co-operation and Development(OECD)proposal for taxation of digital economy constitutes one of the most ambitious projects in the field of taxation and may lead to the most significant reform to international tax rules in the 20th century.Based on a two-pillar approach,Pillar Two of the proposal suggests the adoption of Global Anti-Base Erosion(GloBE)provisions that are aimed at introducing a worldwide minimum tax.In this article,a critical analysis is based that the GloBE proposal suggests that it represents a shift in the OECD policy.As compared to base erosion and profit shifting(BEPS),it jeopardizes the tax sovereignty of jurisdictions and it raises fundamental challenges of implementation,both in terms of amendments to domestic law and conflicts with tax treaties.
文摘The phenomenon of global fragmented production and associated trade in intermediate products,including intangible assets,has changed how economists study globalization and how new public policies are shaped.Understanding cross-border flows of disembodied knowledge,often associated with intellectual property(IP),is essential for analyzing how modern economies operate.Available data to document these international IP-related knowledge flowsdnamely cross-border payments for IPdare distorted by various factors.Tax planning by multinational enterprises has seriously distorted the measurement of cross-border IP flows,affecting national measurements of imports,exports,GDP,and productivity.The tax-induced mismeasurement could be more than 35% of global charges for use of intellectual property,and greater for individual countries,particularly high-taxrate countries.International initiatives to address the effects of tax base erosion,profit shifting,and other statistical initiatives on global value chains will improve future measurements of cross-border IP flows,improving the understanding of both the creation and uses of IP.
文摘Today,international taxation is at an inflection point.The implementation of action plan on base erosion and profit shifing(BEPS)and enforcement of the Belt and Road Initiative are reshaping taxation rules and principles.As a crucial aspect of outbound taxation,foreign tax credit is expected to embrace the normative objectives of the new era,which emphasize the importance of subjecting all trans-border business activities to equitable,efficient,and coordinated taxation.Currently,China's foreign tax credit prescribes in an incompatible pattern;it lacks clear legislative intent,despite marking specific rules with archaic unilateral characters.To reform this regime,legislative principle should reflect the latest consensus on the economic activities'nexus and ensure that the income derived from trans-border transactions falls under a minimum tax.Regarding specific rules,it is strongly suggested that active and passive incomes be distinguished and the equity holding threshold of obtaining indirect credit be lowered.China's foreign tax credit reform should take an inclusive perspective,actively participating in the cooperation between countries.
