Co-Ordination of Corporate Exit Taxation in the Internal Market and Beyond
Corporate exit taxation is an important obstacle to the deepening of economic integration within the internal market and beyond, as it distorts cross-border business activities of multinational enterprises and hinders cross-border business reorganisations. This article argues that the problems related to corporate exit taxation can only be addressed in a satisfactory way through co-ordination. It describes how a co-ordinated corporate exit taxation regime should be designed and how it could be implemented within the EU, in the context of a common corporate tax base or through a targeted harmonisation measure, as well as outside the EU in Double Taxation Conventions.
International Taxation of Risk
The allocation of risk and of the income from risky investment and activities belongs to the central topics of international tax policy today. This fact is highlighted by the current BEPS initiative of G20 and OECD which casts doubt on the recognition of contractual risk allocation within multinational groups and its impact on profit allocation between separate entities within these groups. It is largely felt that “risk shifting” provides the basis for “profit shifting” by multinationals to the detriment of states and domestic competitors.This article tries to address the topic in a generalized fashion. Starting from the findings of economic research with respect to the interaction of risk and taxes in a domestic setting, it draws conclusions for the international situation. It analyses the fiscal interests of source states and residence states and points out that – while risk shifting is essentially tax-neutral – there are three major areas of concern which have to be discussed: asymmetrical risk allocation (i.e. lack of balance between upside and downside potential), taxation of risk premiums and the tax treatment of “hidden intangibles”, i.e. the distinction between risky income and rents. Furthermore the article supports the relevance of ownership and funding for the allocation of risk and income and warns against overstating the notion of “control” and “real activities” when it comes to the recognition of risk. Finally, it should not be overlooked that states benefit from the lack of full loss-compensation in their national tax systems which allows them to tax volatile profits while not giving full credit for volatile losses.
Development of Science and Technology in the Iranian Electric Power Industry: Challenges and Future Progress
This chapter examines four key segments of the electric power industry in Iran: generation, transportation, distribution and consumption. It reviews the method, development, and evolution of electric power generation in the country. Specifically, the chapter reviews the structure of the electric industry, the main players, institutions, standards as well as laws, human resources, technology, the export and import markets, and engineering management of the industry in the country. Finally, the challenges facing the industry will be identified and policy suggestions to remedy the problems will be provided.