International tax planning under the destination-based cash flow tax

Auerbach, Alan J., Devereux, Michael, Keen, Michael and Vella, John International tax planning under the destination-based cash flow tax. National Tax Journal. (Accepted)

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Abstract

This paper considers the implications of the destination-based cash flow tax (DBCFT) for three common ways of shifting taxable profits between countries: through manipulation of transfer prices, the use of debt, and locating intangible assets in low taxed jurisdictions. It shows that none of these planning devices would be available under a DBCFT, if adopted universally. This is because intra-group payments between two countries do not affect tax liabilities in either country . If adopted unilaterally, however, there would be an incentive to shift profit to the adopting country, at the expense of non-adopting countries.

Item Type: Article
Keywords: taxation; finance
Subject(s): Taxation
Centre: Oxford University Centre for Business Taxation
Date Deposited: 13 Dec 2017 15:49
Last Modified: 16 Jan 2018 14:43
Funders: not applicable
URI: http://eureka.sbs.ox.ac.uk/id/eprint/6703

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