Part 1 - AL-Tax

Part 1 - AL-Tax Part 1 - AL-Tax

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Chapter 8Parry (2003) used a model to assess the welfare losses of tax competition andintroduced, as additional scenarios, possibilities of capital flight from the EU, aLeviathan behavior with large states capable of influencing the after-tax rate ofreturn on capital, and noncompetitive governments (i.e. governments that are lesslikely to cut taxes, knowing that others may imitate them). He set the value of welfarecosts of tax competition that he considered ‘significant’ at 5% of capital tax revenues(corresponding to about 0.25–0.75% of GDP). His benchmark result showed that thisvalue is reached for a tax elasticity of capital between 0.3 and 0.9. He then unlockedthe capital supply elasticity at the EU level and allowed it to increase to 0.5 and 1(i.e. capital can progressively flee the EU). These scenarios respectively reduce thewelfare gains of coordination by about 25% and 50%. The ‘Leviathan’ scenariounsurprisingly reduced the welfare gains (although capital taxation may be too lowor too high depending on the parameters of the model). The same applied for thescenario of noncompetitive governments. The magnitude of these results wasbroadly confirmed by a study commissioned by the European Commission fromCopenhagen Economics (2004), in which the various scenarios of full harmonization,and harmonization of the bases with or without a minimum rate and/or equalyieldconstraints delivered welfare gains between 0.02% and 0.21% of GDP.Potential positive gains were also found by Beltendorf et al. (2006) and van der Horstet al. (2006) in two joint studies looking respectively at tax rates harmonization andconsolidation and formula apportionment.The gains may appear relatively small at first sight – and have been depicted assuch by several authors – but they are actually positive (meaning that there arepotential welfare gains in coordinating corporate taxes) and are as large as thoseexpected from some other important EU policies. A 0.5% welfare gain as a meanvalue from Sørensen (2001) compares well with the 0.6–0.7% gain expected from theremoval of all obstacles to the free movements of services stemming from the fullimplementation of the services directive (Copenhagen Economics, 2005a) and withthe 0.5% GDP increase 19 expected from EU enlargement (European commission,2001b). It also corresponds to more than one-fourth of the GDP increase (1.8%) attributableto 10 years of the implementation of the Single Market Programme as estimatedby the European Commission (2003b) (in line with the 1.1–1.5% GDP increaseestimated for the effect of the SMP until 1994 (European Commission, 1996)). 20 Thisresult includes the liberalization of network industries whose own effect is estimatedat about 0.6% of GDP (although Copenhagen Economics (2005b) estimates the totalEU welfare gain of liberalization of network industries at 1.9% of GDP).Finally, it should be noted that these models are by definition a simplificationof reality and do not capture a number of complicating factors (see Parry (2003)197

International Taxation Handbookfor a discussion of some of these). One important point, in light of the 2001 reportfrom the European Commission, is that the models do not capture the welfaregains linked to the decrease in tax compliance and administrative burden that arisefrom the harmonization of the tax bases. Several factors, for example profit-shiftingissues, are usually left out of the analysis. Huizinga and Laeven (2005), however,estimated that profit-shifting activities are substantial in Europe, 21 with Germanybeing the main loser as about one-third of the true profit is shifted out ofGermany. The aggregate loss in tax collected for European governments representsas much as US$2.7 billion a year. Several other distortions, such as location, financialdistortions, and income shifting, and their consequences on tax revenues, havealso been reviewed by de Mooij (2005) in relation to the Dutch economy. Theabsence of cross-border loss offset and the transfer pricing issues have also not (yet)attracted the full attention of modelers.8.9 ConclusionPolicy actions in corporate taxation at the EU level are relatively infrequent. Thisreflects both an institutional design that promotes subsidiarity in tax matters andrather ambiguous results as to both the existence and the likely effects of corporatetax competition in Europe. Although statutory rates have fallen over the last fewdecades, revenues collected from corporate income taxation have been remarkablystable as a percentage of GDP.This does not, however, suggest that there is no need at all for any EU initiative.Several tax obstacles to the implementation of a truly integrated European markethave been identified and there is empirical evidence of varying degrees of tax avoidanceactivities through relocation, the manipulation of transfer pricing, or profitshifting via thin capitalization. Among the comprehensive measures designed totackle tax obstacles to cross-border activities in Europe, the European Commission(2001a) proposed a comprehensive agenda to work out an optional common consolidatedcorporate tax base for companies doing business in Europe.The proposal presents several important technical difficulties that are currentlybeing dealt with by a working group of national and European experts. It neverthelesspromises a quite substantial potential welfare gain for the European Union,thanks to both the coordination of corporate tax policies and the reduced taxcompliance costs that a common tax base would bring. Provided it is well designed,it would also bring additional benefits via cross-border fiscal consolidation andbetter transfer pricing resolutions, two aspects that are costly for both businesses198

International <strong>Tax</strong>ation Handbookfor a discussion of some of these). One important point, in light of the 2001 reportfrom the European Commission, is that the models do not capture the welfaregains linked to the decrease in tax compliance and administrative burden that arisefrom the harmonization of the tax bases. Several factors, for example profit-shiftingissues, are usually left out of the analysis. Huizinga and Laeven (2005), however,estimated that profit-shifting activities are substantial in Europe, 21 with Germanybeing the main loser as about one-third of the true profit is shifted out ofGermany. The aggregate loss in tax collected for European governments representsas much as US$2.7 billion a year. Several other distortions, such as location, financialdistortions, and income shifting, and their consequences on tax revenues, havealso been reviewed by de Mooij (2005) in relation to the Dutch economy. Theabsence of cross-border loss offset and the transfer pricing issues have also not (yet)attracted the full attention of modelers.8.9 ConclusionPolicy actions in corporate taxation at the EU level are relatively infrequent. Thisreflects both an institutional design that promotes subsidiarity in tax matters andrather ambiguous results as to both the existence and the likely effects of corporatetax competition in Europe. Although statutory rates have fallen over the last fewdecades, revenues collected from corporate income taxation have been remarkablystable as a percentage of GDP.This does not, however, suggest that there is no need at all for any EU initiative.Several tax obstacles to the implementation of a truly integrated European markethave been identified and there is empirical evidence of varying degrees of tax avoidanceactivities through relocation, the manipulation of transfer pricing, or profitshifting via thin capitalization. Among the comprehensive measures designed totackle tax obstacles to cross-border activities in Europe, the European Commission(2001a) proposed a comprehensive agenda to work out an optional common consolidatedcorporate tax base for companies doing business in Europe.The proposal presents several important technical difficulties that are currentlybeing dealt with by a working group of national and European experts. It neverthelesspromises a quite substantial potential welfare gain for the European Union,thanks to both the coordination of corporate tax policies and the reduced taxcompliance costs that a common tax base would bring. Provided it is well designed,it would also bring additional benefits via cross-border fiscal consolidation andbetter transfer pricing resolutions, two aspects that are costly for both businesses198

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