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Advanced Introduction to International Tax Law, Second Edition

Reuven S. Avi-Yonah

This second edition of the Advanced Introduction to International Tax Law provides an updated and succinct, yet highly informative overview of the key issues surrounding taxation and international law from Reuven Avi-Yonah, a leading authority on international tax. This small but powerful book surveys the nuances of the varying taxation systems, offering expert insight into the scope, reach and nature of international tax regimes, as well as providing an excellent platform for understanding how the principles of jurisdiction apply to tax and the connected tools that are used by countries in imposing taxes.
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Three steps forward, one step back? Reflections on “Google taxes” and the destination-based corporate tax

Reuven S. Avi-Yonah

Extract

A large puzzle underlies the recent G20 and OECD BEPS project. If the scope of BEPS is as broad as the reports suggest, why are corporate tax revenues in the OECD so robust?

The final OECD report on BEPS Action 11 suggests that BEPS activities result in between $100 and $240 billion in annual lost revenue from corporate income tax (CIT) on a global basis. The wide spread between these two numbers indicates the significant uncertainty involved. In addition, the higher number represents a relatively small portion of total global CIT revenues, since it is only about half of the annual CIT revenue of the US alone. Moreover, overall OECD revenue data do not indicate that BEPS has had a significant impact on CIT revenue, since those have held steady at 8–10 percent of total revenue since the 1980s (i.e., before BEPS became a significant issue).

These data are surprising in light of what we know about the extent of tax avoidance by US multinationals. Currently, US-based multinationals have accumulated over $2.5 trillion in low-tax jurisdictions offshore, and the US tax on that income (most of which has been accumulated since 2005, when a one-year amnesty allowed previous profits to be repatriated) is about $800 billion, which is also the ten-year estimate of the cost of deferral to the US Treasury. These data suggest that if the OECD estimate is right, a very high percentage of total BEPS activity is due to US multinationals.

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