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UK Venture Capital Tax Relief Schemes After Brexit 英国脱欧后的风险投资税收减免计划
Pub Date : 2016-10-31 DOI: 10.2139/ssrn.3453211
A. Harper
Originally published as Finance Act commentary in the British Tax Review this paper begins by briefly examining four technical changes to the UK EIS, SEIS and VCT venture capital tax reliefs made by the UK Finance Act 2016. Detailed consideration is then given to the implications that the UK leaving the European Union might have for the future parameters of these tax reliefs. Written on 31st October 2016 the analysis primarily anticipates that either the UK will sever its ties to the EU without an exit deal of any sort being concluded, or that the UK’s departure from the EU will be facilitated by way of an EU/Canada style trade treaty incorporating the WTO 1994 Uruguay Round Subsidies and Countervailing Measures Agreement. The impact of the EU State aid rules manifested in the Risk Capital Guidelines and the General Block Exemption Regulation are compared and contrasted with those of the WTO SCM agreement. The discussion centres particularly on the constitution of a WTO subsidy in terms of benefit flow-through and the respective concepts of EU selectivity and WTO specificity, concluding that there are a number of significant ambiguities concerning the potential WTO treatment.
本文最初发表于《英国税务评论》(British Tax Review)的《金融法评论》(Finance Act commentary),首先简要考察了2016年《英国金融法案》(UK Finance Act 2016)对英国EIS、SEIS和VCT风险资本税收减免的四项技术变化。然后详细考虑了英国离开欧盟可能对这些税收减免的未来参数产生的影响。这份分析报告撰写于2016年10月31日,主要预测要么英国将在没有达成任何退出协议的情况下切断与欧盟的关系,要么英国将通过欧盟/加拿大式的贸易条约(包括WTO 1994年乌拉圭回合补贴和反补贴措施协议)脱离欧盟。将欧盟国家援助规则在风险资本指南和一般集体豁免规则中所体现的影响与WTO SCM协议的影响进行了比较和对比。讨论特别集中在利益流通方面世贸组织补贴的构成以及欧盟选择性和世贸组织特殊性的各自概念,结论是关于世贸组织可能的待遇有一些重大的含糊不清之处。
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引用次数: 0
Tax Harmonization in the EU: Insights on Political and Legal Fusion Under Neofunctional Rationale 欧盟税收协调:新功能理论下的政法融合透视
Pub Date : 2016-01-16 DOI: 10.2139/ssrn.2716904
Shafi UK Niazi
The traditional narrative is that direct taxes in EU remain non-harmonized since decisions in this domain originate solely from intergovernmental bargains, often exemplified as failure of legal, political and economic integration. The article reviews this conventional notion that European tax harmonization process draws truly on national choices of Member States. The study does not out rightly discard the national role in pooling EU-level tax mandate but rather seeks to assign it a temporal dimension under neofunctional integration model. Considering the intergovernmental decision-making in isolation, akin to that of traditional nation-state in the global arena, may create a misleading conception in the EU context. While European Member States might seem to be the sole actors of EU-level tax policymaking, yet there exist other players that shape or even push members’ decision-making processes. To this end, the study seeks to capture the key developments instrumental to the legal, political and economic fusion in the European construct. It concludes that (direct) tax policy domain – a symbol of fiscal sovereignty of Member States and unspoken supranational regime in EU law – is also not impervious to neofunctional political rationale and consequential processes of law-creation.
传统的说法是,欧盟的直接税仍然不协调,因为这一领域的决定完全源于政府间的讨价还价,往往以法律、政治和经济一体化的失败为例。文章回顾了这一传统观念,即欧洲税收协调进程真正借鉴了成员国的国家选择。这项研究并没有正确地抛弃国家在汇集欧盟层面税收授权中的作用,而是试图在新的功能整合模型下为其分配一个时间维度。孤立地考虑政府间决策,类似于传统民族国家在全球舞台上的决策,可能会在欧盟范围内产生一种误导性的概念。虽然欧盟成员国似乎是欧盟层面税收政策制定的唯一参与者,但还有其他参与者影响甚至推动成员国的决策过程。为此目的,本研究力求捕捉对欧洲结构中法律、政治和经济融合有重要作用的关键发展。它的结论是,(直接)税收政策领域——成员国财政主权和欧盟法律中不言而喻的超国家制度的象征——也并非不受新功能政治理论和法律创造的相应过程的影响。
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引用次数: 1
Tax Noncompliance and Insider Trading 税务违规和内幕交易
Pub Date : 2015-11-26 DOI: 10.2139/ssrn.2476888
Juha-Pekka Kallunki, Jenni Mikkonen, Henrik Nilsson, Hanna Setterberg
This paper explores whether insiders who have shown noncompliance with the tax law (‘noncompliant insiders’) are more prone to exploit their information advantage in insider trading, compared to other insiders (‘compliant insiders’). Our empirical results from analyzing archival data of all insider trades in Sweden show that noncompliant insiders use more of their information advantage to trade their insider stocks shortly before significant stock price changes, compared to compliant insiders. These results remain similar after controlling for various insider- and firm-specific determinants of insider returns, including firm and year fixed effects. We believe that our results are of interest for academics and regulatory authorities monitoring and screening insider trading activity.
本文探讨了与其他内部人(“合规内部人”)相比,表现出不遵守税法的内部人(“不合规内部人”)是否更倾向于利用其在内幕交易中的信息优势。我们通过分析瑞典所有内幕交易的档案数据得出的实证结果表明,与合规的内部人相比,不合规的内部人更多地利用他们的信息优势在股价发生重大变化前不久交易他们的内部人股票。在控制内部人员回报的各种内部和公司特定决定因素后,这些结果仍然相似,包括公司和年度固定效应。我们相信,我们的研究结果对监控和筛选内幕交易活动的学术界和监管机构很有意义。
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引用次数: 11
Taxes and Bank Capital Structure 税收和银行资本结构
Pub Date : 2015-07-03 DOI: 10.2139/ssrn.2519533
G. Schepens
This paper shows that a reduction in tax discrimination between debt and equity funding leads to better capitalized financial institutions. The paper exploits exogenous variation in the tax treatment of debt and equity created by the introduction of a tax shield for equity. The results demonstrate that a more equal treatment of debt and equity increases bank capital ratios, driven by an increase in common equity. The change also leads to a significant reduction in risk taking for ex-ante low capitalized banks. Overall, the findings suggest that tax shields could be a valuable and innovative policy tool for bank regulators.
本文表明,减少债务和股权融资之间的税收歧视导致更好的资本金融机构。本文利用引入股权税盾所产生的债务和股权税收处理的外生变化。结果表明,在普通股本增加的推动下,债务和股本更平等地对待会提高银行的资本比率。这一变化还导致事前低资本银行的风险承担显著减少。总的来说,研究结果表明,对银行监管机构来说,税收盾牌可能是一种有价值的创新政策工具。
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引用次数: 167
Subsidies and Spillovers in a Value Chain World: New Rules Required? 价值链世界中的补贴与溢出效应:需要新规则吗?
Pub Date : 2015-07-01 DOI: 10.2139/ssrn.2637264
B. Hoekman
Assessing the effects of subsidies is complicated, given the need to consider linkages within and across supply chain networks. A precondition for determining whether existing WTO disciplines on subsidies are adequate is better information and more empirical research on the extent to which negative international spillovers are created by prevailing policies. Many of the policies that affect supply chain operations are not considered subsidies under the WTO. There are no rules on subsidies for services or investment incentives. Conversely, some WTO rules may not be appropriate or effective given the increasing prevalence of value chains. There is an urgent need for policy analysis to determine how existing WTO disciplines impact on value chain s and whether and how large the negative spillovers are of national policies. A necessary condition for any such determination is much better data on the measures that are employed by governments around the world, both at the central and sub-central levels.
鉴于需要考虑供应链网络内部和跨供应链网络的联系,评估补贴的影响是复杂的。确定世贸组织关于补贴的现有纪律是否充分的一个先决条件是,对现行政策造成的负面国际溢出效应的程度有更好的信息和更多的实证研究。根据世贸组织的规定,许多影响供应链运作的政策不被视为补贴。没有关于服务补贴或投资激励的规定。相反,鉴于价值链的日益普及,一些世贸组织规则可能不合适或不有效。迫切需要进行政策分析,以确定现有的WTO规则对价值链的影响,以及国家政策的负面溢出效应是否存在以及有多大。做出此类决定的一个必要条件是,世界各国政府(包括中央和地方政府)所采用的措施的数据要好得多。
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引用次数: 5
The Review of Regulatory Documents on Taxation Issues in April-May 2015 2015年4 - 5月税务规范性文件审查
Pub Date : 2015-06-19 DOI: 10.2139/SSRN.2620671
Ludmila Anisimova
In the period under review, a large number of regulatory documents aimed at coping with crisis phenomena in the economy were released. The main guidelines for the RF Government’s acIn the period under review, a large number of regulatory documents aimed at coping with crisis phenomena in the economy were released. The main guidelines for the RF Government’s activities in the period till 2018 (the revised version as of 14 May 2015) and Federal Law No.87-FZ of 20 April 2015 on The Reporting by the Government of the Russian Federation and Information by the Central Bank of the Russian Federation on Implementation of the Plan of Priority Measures Aimed at Ensuring of Sustained Development of the Economy and Social Stability in 2015 were approved; fi nancial agencies approved documents aimed at preventi on of channels of tax evasion (unfortunately, not always indisputable ones); explanations on application of provisions of the Tax Code of the Russian Federation were prepared and regulatory documents of other economic agencies dealing with organization of economic relations in present-day conditions were released. In our view, in the situation of fi nancial instability one of the most complicated and topical lines of the RF Government’s activities is development of the strategy of behavior in respect of natural monopolies and other state monopolies which operate in the economy.vities in the period till 2018 (the revised version as of 14 May 2015) and Federal Law No.87-FZ of 20 April 2015 on The Reporting by the Government of the Russian Federation and Information by the Central Bank of the Russian Federation on Implementation of the Plan of Priority Measures Aimed at Ensuring of Sustained Development of the Economy and Social Stability in 2015 were approved; fi nancial agencies approved documents aimed at prevention of channels of tax evasion (unfortunately, not always indisputable ones); explanations on application of provisions of the Tax Code of the Russian Federation were prepared and regulatory documents of other economic agencies dealing with organization of economic relations in present-day conditions were released. In our view, in the situation of fi nancial instability one of the most complicated and topical lines of the RF Government’s activities is development of the strategy of behavior in respect of natural monopolies and other state monopolies which operate in the economy.
在本报告所述期间,出台了大量旨在应对经济危机现象的规范性文件。在本报告所述期间,俄罗斯联邦政府的主要指导方针和旨在处理经济危机现象的大量规章文件已经公布。批准了俄罗斯联邦政府至2018年期间活动的主要指导方针(截至2015年5月14日的修订版)和2015年4月20日关于俄罗斯联邦政府报告和俄罗斯联邦中央银行关于2015年确保经济持续发展和社会稳定优先措施计划执行情况的第87- fz号联邦法;金融机构批准了旨在防止逃税渠道的文件(不幸的是,这些文件并不总是无可争议的);编写了关于适用俄罗斯联邦税法条款的解释,并发布了其他经济机构关于在当前条件下组织经济关系的规范性文件。我们认为,在金融不稳定的情况下,俄罗斯联邦政府活动中最复杂和最热门的方面之一是制定有关在经济中运作的自然垄断和其他国家垄断的行为战略。批准了2015年4月20日《关于俄罗斯联邦政府报告和俄罗斯联邦中央银行关于2015年确保经济持续发展和社会稳定优先措施计划执行情况的第87- fz号联邦法》(2015年5月14日修订版);金融机构批准了旨在防止逃税渠道的文件(不幸的是,这些文件并不总是无可争议的);编写了关于适用俄罗斯联邦税法条款的解释,并发布了其他经济机构关于在当前条件下组织经济关系的规范性文件。我们认为,在金融不稳定的情况下,俄罗斯联邦政府活动中最复杂和最热门的方面之一是制定有关在经济中运作的自然垄断和其他国家垄断的行为战略。
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引用次数: 0
Closing the Stamp Duty Loophole 填补印花税漏洞
Pub Date : 2015-04-01 DOI: 10.2139/ssrn.2563303
A. Persaud
The purpose of this paper is to estimate how much revenue might feasibly be generated by closing loopholes in the UK Government’s stamp duty tax on share transactions. We focus predominantly on preventing abuse of intermediary relief (sometimes known as the market-makers’ exemption). We use estimates of the elasticity of turnover to an increase in transaction costs, estimates of turnover attributed to market-makers but related to the hedging of derivative transactions by hedge funds and other short-term traders rather than market-making activities and we sum all marginal transaction costs, including price-impact, dealing spreads, clearing and settlement costs. There is a tendency by industry participants to focus on only partial transaction costs, thereby exaggerating the impact of the tax on tunover. We estimate that taking into account the likely reduction in turnover, preventing abuse of the market-makers exemption would raise approximately £1.2bn to £1.8bn in additional tax revenues, leading to an increase in total revenues from £3.1bn to £4.3bn to £4.9bn.
本文的目的是估计通过关闭英国政府对股票交易的印花税漏洞可能产生多少收入。我们主要关注防止滥用中介救济(有时被称为做市商豁免)。我们使用对交易成本增加的周转弹性的估计,归因于做市商的周转估计,但与对冲基金和其他短期交易者对衍生品交易的套期保值有关,而不是做市商活动,我们汇总了所有边际交易成本,包括价格影响、交易价差、清算和结算成本。行业参与者倾向于只关注部分交易成本,从而夸大了税收对营业额的影响。我们估计,考虑到营业额可能减少,防止滥用做市商豁免将增加约12亿至18亿英镑的额外税收收入,从而使总收入从31亿英镑增加到43亿英镑,再增加到49亿英镑。
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引用次数: 1
Dynamic Equilibrium at a Congestible Facility Under Market Power 市场力量下拥挤设施的动态均衡
Pub Date : 2015-03-31 DOI: 10.2139/ssrn.2588949
E. Verhoef, Hugo E. Silva
Various contributions to the recent literature on congestion pricing have demonstrated that when services at a congestible facility are provided by operators with market power, the case in point often being a few airlines jointly using a congested airport, optimal congestion pricing rules deviate from the familiar Pigouvian rule that tolls be equal to the marginal external costs. The reason is that an operator with market power has an incentive to internalize the congestion effects that its customers and vehicles impose upon one-another, so that Pigouvian tolling would lead to overpricing of congestion. More recent contributions to this literature, however, have brought to the fore that when congestion at the facility takes on the form of dynamic bottleneck congestion a la Vickrey (1969), where trip scheduling is the key behavioural margin, there may exist no Nash e quilibrium in arrival schedules for oligopolistic operators also under rather plausible assumptions on parameters. This paper investigates whether in such cases, an equilibrium does exist for another congestion technology, namely the Henderson-Chu dynamic model of flow congestion. We find that a stable and unique equilibrium exists also in cases where it fails to exist under bottleneck congestion (notably when the value of schedule late exceeds the value of travel delays). Our results suggest that self-internalization with only two firms leads to a considerable efficiency gain compared to the atomistic equilibrium (83% or more of the gain from first-best pricing in our numerical exercises).
最近关于拥堵定价的各种文献表明,当一个拥堵设施的服务是由具有市场力量的运营商提供的,例如通常是几家航空公司联合使用一个拥堵的机场,最优拥堵定价规则偏离了我们熟悉的庇古规则,即通行费等于边际外部成本。原因在于,拥有市场支配力的运营商有动力将其客户和车辆相互施加的拥堵效应内部化,因此庇古收费将导致拥堵定价过高。然而,最近对这一文献的贡献表明,当设施的拥堵呈现动态瓶颈拥堵的形式时,如la Vickrey(1969),其中行程调度是关键的行为边际,在相当合理的参数假设下,寡头运营商的到达时间表可能不存在纳什均衡。本文考察了在这种情况下,另一种拥塞技术,即流动拥塞的Henderson-Chu动态模型是否存在均衡。我们发现,在瓶颈拥塞情况下(特别是当调度延迟值超过出行延迟值时),不存在稳定且唯一的均衡也存在。我们的研究结果表明,与原子均衡相比,只有两家公司的自我内部化会带来相当大的效率增益(在我们的数值练习中,从最优定价中获得的增益为83%或更多)。
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引用次数: 5
Empirical Evidence on Tax Cooperation Between Sub-Central Administrations 地方行政机关税收合作的实证研究
Pub Date : 2015-03-02 DOI: 10.2139/ssrn.2580145
J. Duran-Cabré, Alejandro Esteller-Moré, L. Salvadori
The literature on horizontal tax interdependence pays limited attention to interactions in administrative policies, although they can play a large role in determining the amount of tax revenues collected. We investigate the incentives for sub-central tax authority cooperation in a decentralized context, with the aim of identifying the determinants of that cooperation. Our results are congruent with standard theory; in particular, the existence of reciprocity is essential for sharing tax information, but there is sluggishness in this process, which is partly the result of the short-sighted behaviour of tax authorities influenced by budget constraints. Hence, this is good news for the functioning of a decentralized tax administration, as in the medium-long run the gains to be made from sharing tax information are achieved.
关于横向税收相互依赖的文献对行政政策中的相互作用关注有限,尽管它们在决定税收收入方面可以发挥很大作用。我们研究了分权背景下地方中央税务机关合作的激励机制,目的是确定合作的决定因素。我们的结果与标准理论一致;特别是,互惠的存在对于共享税收信息至关重要,但这一过程存在迟缓,部分原因是税务机关受预算约束影响的短视行为。因此,这对于分散的税收管理的运作来说是一个好消息,因为从中长期来看,共享税收信息可以获得收益。
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引用次数: 14
Income Taxation and Equity: New Dominance Criteria and an Application to Romania 所得税与公平:新的主导标准及其在罗马尼亚的应用
Pub Date : 2014-11-12 DOI: 10.2139/ssrn.2523800
P. Brunori, F. Palmisano, Vito Peragine
This paper addresses the problem of the normative evaluation of income tax systems and income tax reforms. While most of the existing criteria, framed in the utilitarian tradition, are uniquely based on information about individual incomes, this paper, building upon the opportunity egalitarian theory, proposes new equity criteria which take into account also the socio-economic characteristics of individuals. Suitable dominance conditions that can be used to rank alternative tax systems are derived by means of an axiomatic approach. Moreover, the theoretical results are used to assess the redistributive effects of an hypothetical tax reform in Romania through a microsimulation analysis.
本文讨论了所得税制度的规范性评价和所得税改革的问题。虽然在功利主义传统框架下的大多数现有标准都是独特地基于个人收入的信息,但本文在机会平等主义理论的基础上,提出了考虑到个人社会经济特征的新的公平标准。通过公理化方法推导出可用于对备选税制进行排序的合适优势条件。此外,通过微观模拟分析,理论结果被用于评估罗马尼亚假设税制改革的再分配效应。
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引用次数: 3
期刊
ERN: Taxation
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