Moreover, corporate cash-flow tax systems do not implement full
neutrality between debt and equity and between newly issued equity and retained
earnings if capital gains at the personal level are taxed upon realisation instead of upon
accrual. Full neutrality will only be achieved if savings are not taxed at the personal level or
if savings receive consumption tax treatment at the personal level as well (but even then,
capital gains would have to be taxed upon accrual).
Otherwise, equity will be tax-preferred
to debt as source of finance.
Countries might implement either a destination-based or an origin-based corporate
cash-flow tax. A destination-based corporate cash-flow tax provides reduced incentives to
corporations to locate in low-tax jurisdictions and it avoids transfer pricing problems.
However, it does not tax the normal return and the economic rents on domestic or foreignowned
domestic capital consumed abroad. Yet, the taxation of income flowing abroad was
one of the important objectives of a corporate tax. A destination-based corporate cash-flow
tax might imply a reduction in tax revenues for exporting countries.
Net importing
countries, on the other hand, might gain. However, countries that create a lot of economic
rents by exporting goods, and if these economic rents are consumed at home, might raise
a lot of tax revenue.
Moreover, destination-based taxation requires border controls to check
whether goods actually have been exported and to ensure that imported goods are taxed.
However, transfer pricing problems
will be present and a source-based corporate cash-flow tax will be sensitive to tax
competition, as corporations face a tax-induced incentive to produce in jurisdictions
where they face the lowest tax rate.
内容と多少違う内容の訳になっていたためです。
訳していただいたのに申し訳ありません。
また、よろしくお願いできればと思います。
今後ともよろしくお願い致します。