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Full-Text Articles in Taxation-Transnational
Folkrättens Indirekta Genomslag Vid Tolkning Av Svenska Skatteavtals Införlivandelagstiftning, Maria Hilling
Folkrättens Indirekta Genomslag Vid Tolkning Av Svenska Skatteavtals Införlivandelagstiftning, Maria Hilling
Maria Hilling
No abstract provided.
A Framework For An Informed Study Of The Realistic Role Of Tax In A Development Agenda, Yariv Brauner
A Framework For An Informed Study Of The Realistic Role Of Tax In A Development Agenda, Yariv Brauner
Yariv Brauner
This article builds on the insights of this development research to develop a new agenda for tax incentives (and equivalent tax measures), the research of their merits when used by developing countries, and their optimal design. The stated goal of these incentives is to attract foreign direct investment, and ultimately enhance economic growth and promote development. Almost all countries use such tax incentives, and business interests strongly support and even demand their use, yet, economic research in general, and the international economic organizations in particular, have been skeptical about their effectiveness." Tax incentives are not only ubiquitous, but also very …
Integration In An Integrating World, Yariv Brauner
Integration In An Integrating World, Yariv Brauner
Yariv Brauner
During the second half of the last century, many countries gradually replaced their so-called classical corporate tax regimes, under which corporate earnings were taxed twice -- once in the hands of the corporation, and again when distributed to corporate shareholders as dividends -- with an integrated regime (imputation), which taxed such earnings only once. The driving force behind this trend was the expectation of significant efficiency gains. This clear and gradual trend has been abruptly reversed with the turn of the century. The phenomenon we call globalization, and in particular the proliferation of cross-border business and investment, has materially contributed …
Value In The Eye Of The Beholder: The Valuation Of Intangibles For Transfer Pricing Purposes, Yariv Brauner
Value In The Eye Of The Beholder: The Valuation Of Intangibles For Transfer Pricing Purposes, Yariv Brauner
Yariv Brauner
This article assesses the desirability of our current, arms' length based, transfer pricing regime by analyzing its theoretical and practical effectiveness in application to transfers of intangibles. A detailed analysis of the practice of valuation of intangibles, which is the key component in the application of this regime, exposes its weaknesses that result in undesirable market incentives. These incentives create a strong bias in favor of large multinational enterprises, yet, even if one favored such bias, it is achieved using an uncontrollable, costly and wasteful legal mechanism. The article particularly criticizes the regime's disregard of the unique characteristics of intangibles …
An International Tax Regime In Crystallization, Yariv Brauner
An International Tax Regime In Crystallization, Yariv Brauner
Yariv Brauner
The grand illusion of a single, worldwide, tax system that will eliminate all international inefficiencies, and assist all the nations of the world to maximize their relative advantages, is, as commonly accepted, utopian. The tax, academic and professional, writing in the field of international taxation, and cross-border interaction, between tax systems and jurisdictions has grown, exponentially, in the last decade, but no significant work has been done to prove, or disprove, the naivety of this hypothesis. Some scholars and tax executives, in certain international organizations, have discussed ideas along this line, but no single organization has, seriously, attempted to promote …
Brain Drain Taxation As Development Policy, Yariv Brauner
Brain Drain Taxation As Development Policy, Yariv Brauner
Yariv Brauner
This article examines the potential use of taxation to generate development funds in connection with the immigration of skilled immigrants from developing into developed countries, known as the "brain drain," if designed according to the principles of the new development agenda. It explains that a tax on the brain drain that has been discussed for several decades, yet considered impossible to administer, may be administratively and legally implementable within the framework of the current international tax regime. It argues that designing such a tax according to the principles of the new development agenda, tying together the collection and use of …
International Trade And Tax Agreements May Be Coordinated, But Not Reconciled, Yariv Brauner
International Trade And Tax Agreements May Be Coordinated, But Not Reconciled, Yariv Brauner
Yariv Brauner
A recent WTO case held the U.S.' export tax subsidies illegal. Despite strong political resistance, which fed a long and costly legislative process, the U.S. recently repealed these subsidies. This case and the U.S. reaction revealed that although the U.S. is the single super economic power, it is not as dominant a player as some portray it. The case also shed light on the tension between the present international trade and tax regimes and the difficulty of applying WTO law to income tax measures. This tension did not escalate earlier mainly because countries tended not to use their income tax …
The Discursive Failure In Comparative Tax Law, Omri Marian
The Discursive Failure In Comparative Tax Law, Omri Marian
Omri Y Marian
Tax comparatists tend to bemoan the grim status of their chosen field. Complaints are aimed both at the scarcity of decent comparative legal tax scholarship, and at the lack of a theoretical foundation for the study of comparative tax law. The purpose of this Article is to portray a more sanguine, yet critical, view of this field. Sanguine, since a sympathetic reading of contemporary comparative tax scholarship demonstrates that there is more than enough such scholarship to generate a lively debate on comparative tax works and their methodologies. Critical, since all of these works fail to produce even the faintest …