A Common Tax Base for Multinational Enterprises in the by Carsten Wendt

By Carsten Wendt

Corporation taxation is a crucial aspect for the institution and the of entirety of the inner marketplace. by contrast heritage, the eu fee recommends the harmonization of the tax base within the eu Union. Carsten Wendt analyzes the need, the concept that in addition to capability benefits and results of a standard tax base for multinational agencies within the eu Union. He addresses very important matters touching on a standard tax base, reminiscent of a definition of the consolidation and the formulation used to allocate the consolidated tax base one of the concerned member states. the writer presents substitute concepts to unravel those concerns and concludes universal tax base as meant via the ecu fee may treatment the various latest tax hindrances for multinational corporations within the ecu.

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Individual equity refers to the relationship between the individual liable to tax and the government that levies the taxes. Inter-nation equity is concerned with the relationship between the country in which the taxpayer is resident and the country in which a taxable event is 3 Guidelines for Income Taxation of Multinational Enterprises 33 realised. In the following two sections, both dimensions of equity are addressed separately. 1 Individual equity Taxes are generally levied in order to finance government expenditure for public needs (see Jachmann, 2000: 9).

2 Boundaries of the Multinational Enterprise As argued before, the theories of foreign direct investment presented so far have dealt with trade and foreign direct investment flows but share a common failure to adequately explain the crucial issue of internalization. They can explain why firms sort into exclusive domestic producers, exporters or foreign direct investors. However, these models cannot explain why some firms outsource while others integrate. In the following, theories addressing the internalization issue of multinational enterprises are presented.

2 Inter-nation equity Jurisdictions are territorially limited. In contrast, economic activities extend across borders. This constellation raises questions of who is entitled to tax income arising from cross-border economic activity and how the potential to extend the jurisdiction’s tax authority outside its own borders should be exercised. Each country involved in cross-border economic activity has an interest to levy income taxes in order to fund government expenditure (see Fohr, 2001: 75). However, neither state has an original right to tax the income in question (see Vogel, 1988: 398).

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