Part 1 - AL-Tax
Part 1 - AL-Tax Part 1 - AL-Tax
Chapter 1AbstractInternational taxation is becoming less and less about national sovereignty and increasinglyabout tax competition and the need for harmonization. While expanding spheres of economicinfluence meant that the first important steps of international taxation arose as the UnitedStates grappled with 50 semi-sovereign tax states and a growing influence around the world,many of our lessons now come from the experiences of the European Union countries. Atthe same time, the economics of international taxation theory increased in sophistication.The confluence of these influences could not come at a better time as emerging nationshave the opportunity to, often for the first time, introduce new and integrated internationaltaxation protocols. These countries can benefit from the collective insights before them,many of which are summarized in the articles assembled in this book.1.1 IntroductionThere was a time, before customs unions, free trade treaties, GATT, and otherpost-WW1 institutions, when international aspects of taxation were confined totariffs and treaties. Innovations in transportation began to open up the trade ingoods. Colonization and the heartland/hinterland political realities set up systemsof trade in services. However, the resulting taxation implications of theseinnovations were often confined to excise taxes and customs duties or the domestictaxation of profits from these new multinational corporations. The spread ofthe Western economic model, ‘innovations’ in taxation avoidance, freer flows ofcapital resulting from balance of trade surpluses and the spread of capitalism allrequired innovations in the treatment of foreign profits, and, as such, the measurementof foreign costs and revenues. This is the traditional scope of internationaltaxation. However, as firms become more clever in adjusting to new taxregimes, as broader customs unions (most notably the EU) give rise to more unifiedinternational taxation principles, and as a greater share of international tradebecomes centered around the movement of services rather than goods, new internationaltaxation principles soon arose. This is especially true as labor more easilycommutes across borders, and as the definition of the value and location of agood or service changes with innovations such as the Internet and supply chainmanagement. The articles in this book describe some of the innovations, in theoryand practice, and their implications on tax policy in the developed andemerging nations.In the first part of the book, we begin by describing the important implicationsof globalization on labor mobility, effective tax rates, and tax competition. In theirquest to meld tax policy with economic growth, policymakers are now delving5
International Taxation Handbookinto the academic literature on international taxation competitiveness to gaininsights into optimal tax policy. The number of variables in play is forcing thisincreased sophistication. At one time, the policymaker could hold hostage theircapital stock, exchange rate, and especially their labor force. Now, however, eventhe productivity of labor easily crosses borders in the Internet era of call-center outsourcing.The virtual worker can be located anywhere, which creates challenges forthe taxation policymaker.In the chapter entitled ‘Summary, Description, and Extensions of the CapitalIncome Effective Tax Rate Literature’, Professors Fernando M.M. Ruiz and MarcelGérard assist us in the theoretical discussion of tax harmonization through theiranalysis of effective tax rates. They make a distinction important in internationaltax planning by differentiating between marginal and average tax rates in environmentswith technological progress, uncertainty, and competitive pressures.Their important conclusions regarding the endogeneity of effective tax rateson international variables is a point particularly relevant for international taxpolicymakers.In a chapter entitled ‘Empirical Models of International Capital-tax Competition’,Professors Robert J. Franzese Jr and Jude C. Hays also model the inter-relationshipbetween domestic and global politics and international tax competition. They createfor us a foundation within which to evaluate international tax policy from a policymaker’sperspective. The goal of any tax policy should be the enhancement of thesocial welfare of the citizenry. Concepts of tax burden and efficiency must inevitablybe used to validate the myriad tax regimes and their effects on international tradeand capital movements. Nations are now coming to realize the strategic interdependencein their tax policymaking. This chapter makes a valuable contribution tothat discussion. The authors point out some surprising implications about tax burdensthat frustrate rather than further the goals of tax policymakers.Professor Gwenaël Piaser continues this line of discussion in the chapter entitled‘Labor Mobility and Income Tax Competition’. The author also stresses the criticalnature of our assumptions of mobility of capital, goods and services, and labor.This chapter streamlines the analysis by considering a two-country model that,while in the abstract, nonetheless nicely parallels the success of some countries,most notably Ireland, in increasing its mix of skilled workers and hence its taxrevenue by decreasing its tax rate. This chapter also provides a nice theoreticalfoundation for some of the experiments currently being considered in the newEastern European EU members.We next follow up this theoretical discussion with a number of policy-orientedchapters devoted to optimal international tax policy in practice. The example of6
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International <strong>Tax</strong>ation Handbookinto the academic literature on international taxation competitiveness to gaininsights into optimal tax policy. The number of variables in play is forcing thisincreased sophistication. At one time, the policymaker could hold hostage theircapital stock, exchange rate, and especially their labor force. Now, however, eventhe productivity of labor easily crosses borders in the Internet era of call-center outsourcing.The virtual worker can be located anywhere, which creates challenges forthe taxation policymaker.In the chapter entitled ‘Summary, Description, and Extensions of the CapitalIncome Effective <strong>Tax</strong> Rate Literature’, Professors Fernando M.M. Ruiz and MarcelGérard assist us in the theoretical discussion of tax harmonization through theiranalysis of effective tax rates. They make a distinction important in internationaltax planning by differentiating between marginal and average tax rates in environmentswith technological progress, uncertainty, and competitive pressures.Their important conclusions regarding the endogeneity of effective tax rateson international variables is a point particularly relevant for international taxpolicymakers.In a chapter entitled ‘Empirical Models of International Capital-tax Competition’,Professors Robert J. Franzese Jr and Jude C. Hays also model the inter-relationshipbetween domestic and global politics and international tax competition. They createfor us a foundation within which to evaluate international tax policy from a policymaker’sperspective. The goal of any tax policy should be the enhancement of thesocial welfare of the citizenry. Concepts of tax burden and efficiency must inevitablybe used to validate the myriad tax regimes and their effects on international tradeand capital movements. Nations are now coming to realize the strategic interdependencein their tax policymaking. This chapter makes a valuable contribution tothat discussion. The authors point out some surprising implications about tax burdensthat frustrate rather than further the goals of tax policymakers.Professor Gwenaël Piaser continues this line of discussion in the chapter entitled‘Labor Mobility and Income <strong>Tax</strong> Competition’. The author also stresses the criticalnature of our assumptions of mobility of capital, goods and services, and labor.This chapter streamlines the analysis by considering a two-country model that,while in the abstract, nonetheless nicely parallels the success of some countries,most notably Ireland, in increasing its mix of skilled workers and hence its taxrevenue by decreasing its tax rate. This chapter also provides a nice theoreticalfoundation for some of the experiments currently being considered in the newEastern European EU members.We next follow up this theoretical discussion with a number of policy-orientedchapters devoted to optimal international tax policy in practice. The example of6