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The Proper Tax Base

The Proper Tax Base Structural Fairness from an International and Comparative Perspective

Author: Yariv Brauner; Martin McMahon
Publisher: Kluwer Law International
ISBN: 9789041132864
Published In: March 2012
Format: Hardback , 280 pages
Jurisdiction: European Union ? Disclaimer:
Countri(es) stated herein are used as reference only

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Contents

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Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform.
- tax expenditure budget construction;
- tax expenditure reporting;
- modern welfare economics as a driver of tax reform;
- grantor trust rules;
- the notion of “horizontal equity”;
- the international tax norm of “income source”;
- transfer pricing; and
- jurisdictional application of VAT.
Specific ongoing reforms in the United States, Australia, and other countries—as well a detailed analysis of the EU’s proposed common consolidated corporate tax base (CCCTB)—are also examined for fairness. As a timely, high-quality resource that effectively tackles an array of salient issues, this is a book that will be read and studied by tax practitioners, corporate tax experts, government tax policy makers, advisers and consultants on the reform and design of tax systems, and international organizations involved in standard setting related to tax administration, as well as academics and researchers.
Part I Tax Expenditures.

Chapter 1 The Staff of the Joint Committee on Taxation Revision of Tax Expenditure Classification Methodology: What Is To Be Made of a Change That Makes No Changes? Paul R. McDaniel.

Chapter 2 Taxing Tax Expenditures? Martin J. McMahon, Jr.

Chapter 3 The Tax Expenditure Concept Globally Miranda Stewart.

Chapter 4 Tax Reform and Tax Expenditures in Australia Richard J. Vann.

Chapter 5 Tax Reform Paul McDaniel Style: The Repeal of the Grantor Trust Rules Laura E. Cunningham & Noel B. Cunningham.

Part II The Fair Tax Base and International Tax Reform.

Chapter 6 Horizontal Equity Revisited James Repetti & Diane Ring.

Chapter 7 What Is This Thing Called Source?Lawrence Lokken.

Chapter 8 Formula Based Transfer Pricing Yariv Brauner.

Part III A Comparative Perspective

Chapter 9 The EU proposed CCCTB—Some Tax Treaty Issues Kees van Raad.

Chapter 10 Shared Legal Orders: Some Thoughts about the Influence of EU Case Law on International Tax Law Rules of the EU Member States Irene J.J. Burgers.

Chapter 11 Intra Group Loans—A Swedish Perspective Bertil Wiman.

Chapter 12 European VAT and Jurisdiction to Tax Antonio Vázquez del Rey.