International taxation is evolving in response to globalization, capital mobility, and the increased trade in services, and introduces international tax practitioner, student and researcher to the theory, practice, and international examples of the changing landscape. Models of tax competition in a flat and connected world are very different than those necessary to ensure compliance in a world dominated by cross-border flows of goods and repatriation of profits. Taxes on consumption, e-commerce, and services are looming innovations in future of international taxation. Tax coordination and standardization are immense challenges in a world in which the movement of value is increasingly subtle and hard to detect. And as corporations and individuals become more sophisticated in the internationalization of flows of capital, our models must become more sophisticated in their scope and inclusion. In the era when trade was dominated by the exchange of manufactured goods, international taxation was designed to protect domestic industries, create tax revenue, prevent evasion, and promote compliance. The traditional toolbox of customs duties, tariffs, and taxes on repatriated profits must be augmented as the movement of goods across borders represents a much smaller fraction of trade and as international taxation policy is increasingly used to attract foreign corporations rather than discourage branch offices. International taxation models that can better tax services, track international flows of capital, and allow a nation to compete in a world market for capital formation are the tools of the modern tax practitioner. International tax policy is now viewed as an integral part of economic policy. This approach is bound to accelerate as the world becomes increasingly flat and better connected. Economic progress is more and more influenced by the movement of services and information, movements that are no longer through ports but through fiber optic lines. This book contributes to the growing literature on international taxation by bringing together theory and experience, current practices and innovation, and our current understanding of some of the challenges now facing and arguably frustrating current international taxation policy. The book will create new avenues of research for scholars, a new awareness for students of International Taxation, and new possibilities for international tax practitioners. The models and examples presented here suggest that there are serious problems with measurability of flows of services and information, and points to an increasingly need for greater harmonization of international taxation, perhaps through coordinated consumption-tax oriented approaches.
Section 1 - International Taxation Theory; The evolution of international taxation; Summary, description and extensions of the capital income effective tax rate literature; Empirical modeling of spatial interdependence in tax competition; Labor mobility and income tax competition; Section 2 - Optimal International Taxation in Practice-Innovations and the EU; Taxable asset sales in securitization; Globalization, multinationals and tax base allocation: advance pricing agreements as shifts in international taxation?; Documentation of transfer pricing: on the nature of arm?s length analysis; Corporate tax competition and coordination in the European Union: What do we know? Where do we stand?; Corporate taxation in Europe: competitive pressure and cooperative targets; The economics of taxing cross-border savings income: an application to the EU savings tax; Tax misery and tax happiness: a comparative study of selected Asian countries; Section 3 - Global Challenges and Global Innovations; The ethics of tax evasion: lessons for transitional economies; Money laundering: every financial transaction leaves a paper trail; Tax effects in the valuation of multinational corporations: the Brazilian experience; The economic impacts of trade agreements and tax reforms in Brazil: some implications for accounting research
