International income allocation under EU tax law tinker, tailor, soldier, sailor Daniel S. Smit
By: Smit, Daniël S
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Material type: 
ArticlePublisher: 2017Subject(s): IMPUTACIÓN DE RENTAS | IMPUESTOS | EMPRESAS MULTINACIONALES | EVASION FISCAL | EROSIÓN DE LA BASE IMPONIBLE Y TRASLADO DE BENEFICIOS | PREVENCIÓN | FISCALIDAD INTERNACIONAL | UNION EUROPEA | ELUSION FISCAL
In:
EC Tax Review v. 26, n. 2, April 2017, p. 67-74Summary: The current European approach to tackle tax avoidance by multinational firms focuses too much on treating the symptoms instead ofthe causes of Base Erosion and Profit Shifting. Under the current rules, business profits should ultimately be taxed once somewhere.But in which country, that doesn.t alwaysreally seem to matter. This is not in line with the principle embraced by the EU and theOECD that companies should be taxed in the country where the profit-generating activities take place. In the author.s opinion, adifferent approach should be developed. A more fundamental approach to the root causes of corporatetax avoidance is needed. Intaxing multinationals, there should be more focus on economic reality in which multinationals operate. To that end, one would needto determine in which place the activities take place and which value one should attribute to them, based on the arm.s length standard.Such an approach woulddo more justice to the principle that profit should be taxed where it is generated.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| IEF | OP 2141-B/2017/2-2 (Browse shelf) | Available | OP 2141-B/2017/2-2 |
Disponible también en línea a través de la Biblioteca del Instituto de Estudios Fiscales. Resumen. Conclusión.
The current European approach to tackle tax avoidance by multinational firms focuses too much on treating the symptoms instead ofthe causes of Base Erosion and Profit Shifting. Under the current rules, business profits should ultimately be taxed once somewhere.But in which country, that doesn.t alwaysreally seem to matter. This is not in line with the principle embraced by the EU and theOECD that companies should be taxed in the country where the profit-generating activities take place. In the author.s opinion, adifferent approach should be developed. A more fundamental approach to the root causes of corporatetax avoidance is needed. Intaxing multinationals, there should be more focus on economic reality in which multinationals operate. To that end, one would needto determine in which place the activities take place and which value one should attribute to them, based on the arm.s length standard.Such an approach woulddo more justice to the principle that profit should be taxed where it is generated.
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