Even though the New Zealand courts have been interpreting this legislation for over 130 years, there is no doubt that applying the anti-avoidance rules is a difficult task. This is why it is common for judges to come to different conclusions or even arrive at the same conclusion through a different reasoning process. In Frucor Muir J so rightly observed, “Benchmarking against parliamentary intention, for all the appropriateness of the exercise, can be an elusive quest.” This article looks at the development of the general anti-avoidance rule in New Zealand in the specific context of the impending appeal of the Frucor case from the Court of Appeal to the Supreme Court. This article begins with an exposition of the test in New Zealand before highlighting the significance of the approach in Ben Nevis from an economic substance perspective. In the light of this analysis, it then examines how the law, specifically the Parliamentary contemplation test, should be applied in expenditure related tax avoidance cases. The conclusion reached is that the Parliamentary intention behind part D of the Income Tax Act is to provide a deduction for taxpayers. This deduction, however, ought not to be available when the expense, viewed in a commercially and economically realistic way, is not in economic substance borne by the taxpayer. This is an example where the line between acceptable tax planning and unacceptable tax avoidance is crossed and the analysis above therefore suggests the Court of Appeal were right to consider it in the latter category of transaction. The nature of tax planning and tax avoidance necessitates an approach from Parliament that, in the hands of the judges, is both flexible and responsive. After more than a decade since the Supreme Court delivered the Ben Nevis judgment, one can see that the New Zealand legislation and case law is robust, challenging and effective against aggressive tax avoidance behaviour. On balance, despite the lack of commercial certainty, this is desirable.
{"title":"Discerning Commercial and Economic Reality: Applying the GAAR to Frucor","authors":"C. Elliffe","doi":"10.2139/SSRN.3833209","DOIUrl":"https://doi.org/10.2139/SSRN.3833209","url":null,"abstract":"Even though the New Zealand courts have been interpreting this legislation for over 130 years, there is no doubt that applying the anti-avoidance rules is a difficult task. This is why it is common for judges to come to different conclusions or even arrive at the same conclusion through a different reasoning process. In Frucor Muir J so rightly observed, “Benchmarking against parliamentary intention, for all the appropriateness of the exercise, can be an elusive quest.” This article looks at the development of the general anti-avoidance rule in New Zealand in the specific context of the impending appeal of the Frucor case from the Court of Appeal to the Supreme Court. \u0000 \u0000This article begins with an exposition of the test in New Zealand before highlighting the significance of the approach in Ben Nevis from an economic substance perspective. In the light of this analysis, it then examines how the law, specifically the Parliamentary contemplation test, should be applied in expenditure related tax avoidance cases. \u0000 \u0000The conclusion reached is that the Parliamentary intention behind part D of the Income Tax Act is to provide a deduction for taxpayers. This deduction, however, ought not to be available when the expense, viewed in a commercially and economically realistic way, is not in economic substance borne by the taxpayer. This is an example where the line between acceptable tax planning and unacceptable tax avoidance is crossed and the analysis above therefore suggests the Court of Appeal were right to consider it in the latter category of transaction. \u0000 \u0000The nature of tax planning and tax avoidance necessitates an approach from Parliament that, in the hands of the judges, is both flexible and responsive. After more than a decade since the Supreme Court delivered the Ben Nevis judgment, one can see that the New Zealand legislation and case law is robust, challenging and effective against aggressive tax avoidance behaviour. On balance, despite the lack of commercial certainty, this is desirable.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-04-24","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"80581944","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The G20/OECD Inclusive Framework is currently deliberating an effective international minimum tax as Pillar Two of its work on the tax challenges arising from digitalization. Political agreement on the so-called Global Anti-Base Erosion Proposal (GloBE) is sought for summer 2021 and prospects currently look good, in particular due to its full endorsement by the Biden administration. This paper outlines the developments leading up to the October 2020 Blueprint on GloBE and provides an assessment of its policy rationale and of certain objections raised in public hearings and in literature. Moreover, the paper critically analyses some of GloBE’s key design features; it also shortly addresses its compatibility with tax treaty law and simplification measures.
This paper will be published in the OUP Handbook of International Tax Law (F. Haase, G. Kofler eds., Oxford University Press 2021 forthcoming)
{"title":"International Effective Minimum Taxation – analysis of GloBE (Pillar Two)","authors":"J. Englisch","doi":"10.2139/ssrn.3829104","DOIUrl":"https://doi.org/10.2139/ssrn.3829104","url":null,"abstract":"The G20/OECD Inclusive Framework is currently deliberating an effective international minimum tax as Pillar Two of its work on the tax challenges arising from digitalization. Political agreement on the so-called Global Anti-Base Erosion Proposal (GloBE) is sought for summer 2021 and prospects currently look good, in particular due to its full endorsement by the Biden administration. This paper outlines the developments leading up to the October 2020 Blueprint on GloBE and provides an assessment of its policy rationale and of certain objections raised in public hearings and in literature. Moreover, the paper critically analyses some of GloBE’s key design features; it also shortly addresses its compatibility with tax treaty law and simplification measures.<br><br>This paper will be published in the OUP Handbook of International Tax Law (F. Haase, G. Kofler eds., Oxford University Press 2021 forthcoming)","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-04-18","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"85297511","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The operative order in the case, titled Bangalore Club v. Commissioner of Wealth Tax & Anr., is welcome. But the pleasant reception cannot possibly extend to the ratio it is premised in. This perplexing opinion is based on the repeated attempts by income and wealth tax authorities to invade the domain of what is traditionally reserved for indirect taxation, and the act of the Hon’ble Supreme Court in entertaining it. When the movement of money is such that there is no augmentation in one’s financial position, the question of direct tax statutes applying needn’t arise in the first place. The mere consideration of these misconceived attempts in assessment can drag the assessee through a layered judicial/quasi-judicial adjudication for years. But despite these being the precise circumstances governing this case, the Hon’ble Supreme Court elected to indulge the authorities in considering the impossible application of a provision belonging to the realm of taxation of the former’s choosing: direct taxation. If the Court wants to secure both the goals of pruning futile cases at the entry-level and to advance commercial certitude, it will have to adopt the test it has been toying with for decades: the filter of direct/indirect tax distinction. If the case has elements that make the taxable event exclusive to indirect taxation, the assertion of a direct tax provision, then, can be dismissed at the very outset. No case can be more unequivocal in evincing loss in wealth on account of a failed trade, such as this. More pertinently, no case had the factual matrix as fertile as it was in this case, for consolidating a better screening mechanism in tax disputes.
{"title":"Opportunity Cost or Regrettable Oversight: Bangalore Club v. Commissioner of Wealth Tax & Anr.","authors":"Y. Sinha","doi":"10.2139/ssrn.3795961","DOIUrl":"https://doi.org/10.2139/ssrn.3795961","url":null,"abstract":"The operative order in the case, titled Bangalore Club v. Commissioner of Wealth Tax & Anr., is welcome. But the pleasant reception cannot possibly extend to the ratio it is premised in. This perplexing opinion is based on the repeated attempts by income and wealth tax authorities to invade the domain of what is traditionally reserved for indirect taxation, and the act of the Hon’ble Supreme Court in entertaining it. When the movement of money is such that there is no augmentation in one’s financial position, the question of direct tax statutes applying needn’t arise in the first place. The mere consideration of these misconceived attempts in assessment can drag the assessee through a layered judicial/quasi-judicial adjudication for years. But despite these being the precise circumstances governing this case, the Hon’ble Supreme Court elected to indulge the authorities in considering the impossible application of a provision belonging to the realm of taxation of the former’s choosing: direct taxation. If the Court wants to secure both the goals of pruning futile cases at the entry-level and to advance commercial certitude, it will have to adopt the test it has been toying with for decades: the filter of direct/indirect tax distinction. If the case has elements that make the taxable event exclusive to indirect taxation, the assertion of a direct tax provision, then, can be dismissed at the very outset. No case can be more unequivocal in evincing loss in wealth on account of a failed trade, such as this. More pertinently, no case had the factual matrix as fertile as it was in this case, for consolidating a better screening mechanism in tax disputes.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-03-02","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"85392774","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2021-02-15DOI: 10.18356/2076099x-28-1-2
Alex Cobham, P. Janský, C. Jones, Yama Temouri
This paper evaluates the Common Consolidated Corporate Tax Base (CCCTB) recently proposed by the European Commission. We find that if the CCCTB is introduced as it is currently proposed (including loss consolidation), then it is likely to impose large tax revenue costs of about one fifth of the corporate tax base. Second, we show that an application of the CCCTB proposals at only the European Union (EU) level would overlook the extent of profit shifting out of the EU and could lock in further unnecessary revenue losses. Third, major EU profit-shifting countries such as Luxembourg, Ireland and the Netherlands may experience significant revenue losses. Based on our analysis, the main policy recommendation is to consider extending the approach to a worldwide system, which would simultaneously deal with profit shifting within and out of the EU, and appears to offer the best prospect for revenue-positive, welfare-enhancing reform. For this to be viable, an immediate priority is to collate cross-country-comparable data and provide precise assessments of the range of policy scenarios.
{"title":"An Evaluation of the Effects of the European Commission’s Proposals for the Common Consolidated Corporate Tax Base","authors":"Alex Cobham, P. Janský, C. Jones, Yama Temouri","doi":"10.18356/2076099x-28-1-2","DOIUrl":"https://doi.org/10.18356/2076099x-28-1-2","url":null,"abstract":"This paper evaluates the Common Consolidated Corporate Tax Base (CCCTB) recently proposed by the European Commission. We find that if the CCCTB is introduced as it is currently proposed (including loss consolidation), then it is likely to impose large tax revenue costs of about one fifth of the corporate tax base. Second, we show that an application of the CCCTB proposals at only the European Union (EU) level would overlook the extent of profit shifting out of the EU and could lock in further unnecessary revenue losses. Third, major EU profit-shifting countries such as Luxembourg, Ireland and the Netherlands may experience significant revenue losses. Based on our analysis, the main policy recommendation is to consider extending the approach to a worldwide system, which would simultaneously deal with profit shifting within and out of the EU, and appears to offer the best prospect for revenue-positive, welfare-enhancing reform. For this to be viable, an immediate priority is to collate cross-country-comparable data and provide precise assessments of the range of policy scenarios.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-02-15","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"79753893","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
How to tax capital income is a critical issue today. The realization rule—requiring that property usually must be sold before gains are taxed—is central to taxing capital income, but often decreases the efficiency, equity, and simplicity of the tax system. Estimates suggest that the realization rule costs the government over $2 trillion over 10 years. Given these problems, it is unclear why the rule exists for assets that are easy to value and sell. Scholars have long speculated about the role of the public’s views here, but little is known empirically about them. We conduct the first survey experiment to understand the psychology of the realization rule, which has broad implications for the taxation of capital income. We have three main findings. First, respondents strongly prefer to wait to tax gains on stocks until sale: 75% to 25%. This pattern persists across a variety of other assets and policy framings: indeed, nearly half of those without stock prefer raising everyone’s taxes (including their own) to taxing unsold stock gains. But the flip side is that there is surprisingly strong support for taxing gains on assets at sale or transfer, including at death, in areas where current law never taxes those gains. Second, these views change only modestly after randomized participants observe a policy debate composed of videos explaining both the pros and cons of taxing before sale, though the pro and con treatments have large effects individually. And, third, among many possible explanations of these attitudes, we find particular evidence for four: using a different mental account for unsold gains than other ways of getting richer; a tendency to support the status quo; concerns about complexity; and a desire to tax consumption, not income, in the context of capital gains.
{"title":"The Psychology of Taxing Capital Income: Evidence from a Survey Experiment on the Realization Rule","authors":"Zachary D. Liscow, Edward G. Fox","doi":"10.2139/SSRN.3848064","DOIUrl":"https://doi.org/10.2139/SSRN.3848064","url":null,"abstract":"How to tax capital income is a critical issue today. The realization rule—requiring that property usually must be sold before gains are taxed—is central to taxing capital income, but often decreases the efficiency, equity, and simplicity of the tax system. Estimates suggest that the realization rule costs the government over $2 trillion over 10 years. Given these problems, it is unclear why the rule exists for assets that are easy to value and sell. Scholars have long speculated about the role of the public’s views here, but little is known empirically about them. We conduct the first survey experiment to understand the psychology of the realization rule, which has broad implications for the taxation of capital income. \u0000 \u0000We have three main findings. First, respondents strongly prefer to wait to tax gains on stocks until sale: 75% to 25%. This pattern persists across a variety of other assets and policy framings: indeed, nearly half of those without stock prefer raising everyone’s taxes (including their own) to taxing unsold stock gains. But the flip side is that there is surprisingly strong support for taxing gains on assets at sale or transfer, including at death, in areas where current law never taxes those gains. Second, these views change only modestly after randomized participants observe a policy debate composed of videos explaining both the pros and cons of taxing before sale, though the pro and con treatments have large effects individually. And, third, among many possible explanations of these attitudes, we find particular evidence for four: using a different mental account for unsold gains than other ways of getting richer; a tendency to support the status quo; concerns about complexity; and a desire to tax consumption, not income, in the context of capital gains.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-01-27","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"80338194","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
In this study, we investigate the effect of the protection of trade secrets through the adoption of the inevitable disclosure doctrine (IDD) by US state courts on corporate tax avoidance. We suggest a positive impact of IDD adoption on tax avoidance because IDD adoption reduces information transparency by increasing the benefit of nondisclosure and, hence, creates greater opportunities for firms to engage in more aggressive tax avoidance activities. Based on a large sample of US firms between 1977 and 2011, we find a significant increase in tax avoidance for firms in states that have adopted the IDD, compared with firms in states that have not adopted it. We further show that the impact of the IDD on corporate tax avoidance is more salient in firms with lower internal information quality. Our findings have important implications for both investors and regulators.
{"title":"The Inevitable Disclosure Doctrine and Corporate Tax Avoidance","authors":"R. Ding, S. Sainani, J. Z. Zhang","doi":"10.2139/ssrn.3764839","DOIUrl":"https://doi.org/10.2139/ssrn.3764839","url":null,"abstract":"In this study, we investigate the effect of the protection of trade secrets through the adoption of the inevitable disclosure doctrine (IDD) by US state courts on corporate tax avoidance. We suggest a positive impact of IDD adoption on tax avoidance because IDD adoption reduces information transparency by increasing the benefit of nondisclosure and, hence, creates greater opportunities for firms to engage in more aggressive tax avoidance activities. Based on a large sample of US firms between 1977 and 2011, we find a significant increase in tax avoidance for firms in states that have adopted the IDD, compared with firms in states that have not adopted it. We further show that the impact of the IDD on corporate tax avoidance is more salient in firms with lower internal information quality. Our findings have important implications for both investors and regulators.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-01-10","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"76751797","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Jost H. Heckemeyer, Katharina Nicolay, Christoph Spengel
As part of its action plan against base erosion and profit shifting(BEPS), the OECD (2015) has proposed six indicators to measure profit shifting activity. These indicators add to past and ongoing efforts in academic tax research to empirically identify the scale and tax sensitivity of international profit shifting. In this paper, we discuss whether the proposed OECD indicators indeed represent methodological advances and critically assess their informative value. While a certain need for “easy-access” indicators to measure the relevance of the base erosion problem seems justified, our discussion reveals that the indicators come up with certain shortcomings, many of them acknowledged by the OECD (2015) itself, that pre-vent them from reliably tracing profit shifting activity in available international data. With one notable exception, the OECD's indicators lack consistent counterfactuals and comparison groups which are essential benchmarks for the observed data. Even the most promising approaches require representative and timely data that covers firms' global activity, including tax haven operations. With better access to such high-quality micro-level data, it will be more promising to empirically isolate the effects of profit shifting from relocations of real economic activity and value creation.
{"title":"What Will the OECD BEPS Indicators Indicate?","authors":"Jost H. Heckemeyer, Katharina Nicolay, Christoph Spengel","doi":"10.2139/ssrn.3783644","DOIUrl":"https://doi.org/10.2139/ssrn.3783644","url":null,"abstract":"As part of its action plan against base erosion and profit shifting(BEPS), the OECD (2015) has proposed six indicators to measure profit shifting activity. These indicators add to past and ongoing efforts in academic tax research to empirically identify the scale and tax sensitivity of international profit shifting. In this paper, we discuss whether the proposed OECD indicators indeed represent methodological advances and critically assess their informative value. While a certain need for “easy-access” indicators to measure the relevance of the base erosion problem seems justified, our discussion reveals that the indicators come up with certain shortcomings, many of them acknowledged by the OECD (2015) itself, that pre-vent them from reliably tracing profit shifting activity in available international data. With one notable exception, the OECD's indicators lack consistent counterfactuals and comparison groups which are essential benchmarks for the observed data. Even the most promising approaches require representative and timely data that covers firms' global activity, including tax haven operations. With better access to such high-quality micro-level data, it will be more promising to empirically isolate the effects of profit shifting from relocations of real economic activity and value creation.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2021-01-01","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"75630291","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
The paper is focused on the field of real property taxation in Slovakia, from a legal-budgetary point of view, at the local level (the City of Košice). The scientific goal of the paper is to assess the development in the total revenue, tax revenue and revenue from real property taxation in component-wise structure (revenue from the taxation of land, buildings and flats and non-residential premises) within the period from 2005 to 2019, as well as the search for causal relations between legislation and reported revenue. Within the first stage of targeted research; the authors applied standard scientific methods and procedures, namely the study and analysis of legislation (selected laws and generally binding regulations), the database of available and requested numerical data and information, which were provided by the selected subject of local self-government - the City of Košice; in the second stage of targeted research the authors created through abstraction, comparison, induction and deduction their own results and conclusions, which are presented in this paper in textual and graphical forms.
{"title":"The Development of Real Property Tax - The Case of City of Košice","authors":"Anna Vartašová, Karolína Červená","doi":"10.2139/ssrn.3769820","DOIUrl":"https://doi.org/10.2139/ssrn.3769820","url":null,"abstract":"The paper is focused on the field of real property taxation in Slovakia, from a legal-budgetary point of view, at the local level (the City of Košice). The scientific goal of the paper is to assess the development in the total revenue, tax revenue and revenue from real property taxation in component-wise structure (revenue from the taxation of land, buildings and flats and non-residential premises) within the period from 2005 to 2019, as well as the search for causal relations between legislation and reported revenue. Within the first stage of targeted research; the authors applied standard scientific methods and procedures, namely the study and analysis of legislation (selected laws and generally binding regulations), the database of available and requested numerical data and information, which were provided by the selected subject of local self-government - the City of Košice; in the second stage of targeted research the authors created through abstraction, comparison, induction and deduction their own results and conclusions, which are presented in this paper in textual and graphical forms.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2020-12-20","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"81836820","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
Pub Date : 2020-12-09DOI: 10.18601/16926722.n18.09
Oscar Stanley Pineda Viana
Spanish Abstract: El artículo presenta información fehaciente, clara y precisa acerca de las principales medidas en materia impositiva que El Salvador y su Administración Tributaria adoptaron con ocasión de la pandemia por el covid-19, declarada por la Organización Mundial de la Salud a partir del mes de marzo de 2020; el impacto fiscal de la pandemia es descrito por el Ministerio de Hacienda de El Salvador en su página web: “De acuerdo al FMI (Fondo Monetario Internacional) la caída en los ingresos será el principal responsable del aumento en el déficit fiscal de aproximadamente 8.75% respecto al PIB; […] la calificadora de riesgo Fitch, en su más reciente actualización de calificación de riesgo indicó que la caída esperada de ingresos como efecto de la contracción económica podría representar un 15% respecto al 2019” (Ministerio de Hacienda, s.f.).
English Abstract: We wish to provide the reader with reliable, clear and precise information on the main measures in tax matters that El Salvador and its Tax Administration (TA) adopted, on the occasion of the Pandemic by covid-19 as of March 2020. The fiscal impact of the pandemic is described by the Ministry of Finance of El Salvador on its website: “According to the IMF (International Monetary Fund) the fall in income will be the main responsible for the increase in the fiscal deficit of approximately 8.75% with respect to the GDP; […] the risk rating agency Fitch, in its most recent risk rating update, indicated that the expected drop in income as a result of the economic contraction could represent 15% compared to 2019” (Ministerior de Hacienda de El Salvador, s.f.).
[Abstract:这篇文章介绍了正宗,清晰和准确的信息讨论税收方面的主要措施,萨尔瓦多和税务管理为主covid-19蔓延之际,世界卫生组织宣布2020年3月起;所述这一大的财政影响萨尔瓦多财政部在其网站:“根据imf(国际货币基金组织(international monetary fund)将收入下降主要负责在财政赤字对国内生产总值约为8.75%;[…]风险评级机构惠誉(Fitch)在其最新的风险评级更新中表示，与2019年相比，经济收缩导致的预期收入下降可能高达15%”(财政部，s.f.)。英文摘要:我们希望向读者提供关于萨尔瓦多及其税务当局在2020年3月covid-19大流行期间采取的主要税收措施的可靠、清晰和准确的信息。对财政The impact of The virus is The Ministry of Finance of萨尔瓦多on its website:“to The IMF(国际货币基金)The fall in收入将主要负责《The增加财政赤字约8.75% with respect to The生产总值;[…]风险评级机构惠誉在其最近的风险评级更新中指出，与2019年相比，经济收缩导致的预期收入下降可能高达15%”(萨尔瓦多财政部，s.f.)。
{"title":"Medidas adoptadas por el Gobierno de El Salvador en el contexto de la pandemia del covid-19 (Measures Taken by the Government of El Salvador in the Context of the Pandemic for the COVID-19)","authors":"Oscar Stanley Pineda Viana","doi":"10.18601/16926722.n18.09","DOIUrl":"https://doi.org/10.18601/16926722.n18.09","url":null,"abstract":"<b>Spanish Abstract:</b> El artículo presenta información fehaciente, clara y precisa acerca de las principales medidas en materia impositiva que El Salvador y su Administración Tributaria adoptaron con ocasión de la pandemia por el covid-19, declarada por la Organización Mundial de la Salud a partir del mes de marzo de 2020; el impacto fiscal de la pandemia es descrito por el Ministerio de Hacienda de El Salvador en su página web: “De acuerdo al FMI (Fondo Monetario Internacional) la caída en los ingresos será el principal responsable del aumento en el déficit fiscal de aproximadamente 8.75% respecto al PIB; […] la calificadora de riesgo Fitch, en su más reciente actualización de calificación de riesgo indicó que la caída esperada de ingresos como efecto de la contracción económica podría representar un 15% respecto al 2019” (Ministerio de Hacienda, s.f.).<br><br><b>English Abstract:</b> We wish to provide the reader with reliable, clear and precise information on the main measures in tax matters that El Salvador and its Tax Administration (TA) adopted, on the occasion of the Pandemic by covid-19 as of March 2020. The fiscal impact of the pandemic is described by the Ministry of Finance of El Salvador on its website: “According to the IMF (International Monetary Fund) the fall in income will be the main responsible for the increase in the fiscal deficit of approximately 8.75% with respect to the GDP; […] the risk rating agency Fitch, in its most recent risk rating update, indicated that the expected drop in income as a result of the economic contraction could represent 15% compared to 2019” (Ministerior de Hacienda de El Salvador, s.f.).","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2020-12-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"73032339","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
This study compares the top corporate tax rates in the People’s Republic of China, Hong Kong, Macau and Taiwan from 1980-2020, using Tax Foundation data.
{"title":"A Comparison of Corporate Tax Rates in the Four Chinas: 1980–2020","authors":"Robert W. McGee","doi":"10.2139/ssrn.3746077","DOIUrl":"https://doi.org/10.2139/ssrn.3746077","url":null,"abstract":"This study compares the top corporate tax rates in the People’s Republic of China, Hong Kong, Macau and Taiwan from 1980-2020, using Tax Foundation data.","PeriodicalId":54058,"journal":{"name":"EJournal of Tax Research","volume":null,"pages":null},"PeriodicalIF":0.3,"publicationDate":"2020-12-09","publicationTypes":"Journal Article","fieldsOfStudy":null,"isOpenAccess":false,"openAccessPdf":"","citationCount":null,"resultStr":null,"platform":"Semanticscholar","paperid":"88922136","PeriodicalName":null,"FirstCategoryId":null,"ListUrlMain":null,"RegionNum":0,"RegionCategory":"","ArticlePicture":[],"TitleCN":null,"AbstractTextCN":null,"PMCID":"","EPubDate":null,"PubModel":null,"JCR":null,"JCRName":null,"Score":null,"Total":0}
京公网安备 11010802042870号
京ICP备2023020795号-1
扫码关注我们
求助内容：
应助结果提醒方式：