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Informacje o czasopiśmie
Format
Czasopismo
eISSN
2246-1809
Pierwsze wydanie
08 Sep 2014
Częstotliwość wydawania
1 raz w roku
Języki
Angielski

Wyszukiwanie

Tom 2019 (2019): Zeszyt 1 (January 2019)

Informacje o czasopiśmie
Format
Czasopismo
eISSN
2246-1809
Pierwsze wydanie
08 Sep 2014
Częstotliwość wydawania
1 raz w roku
Języki
Angielski

Wyszukiwanie

5 Artykułów

Article

Otwarty dostęp

Acceptable levels of tax risk as a metric of corporate tax responsibility: theory, and a survey of practice

Data publikacji: 15 Jun 2019
Zakres stron: 1 - 15

Abstrakt

Abstract

Prescribed levels of acceptable tax risk are increasingly used to articulate degrees of corporate tax responsibility, but the theoretical basis for doing so is not well established. This article (i) develops a theory of the relationship between tax risk and tax responsibility and (ii) shows that acceptable levels of tax risk could be used as a meaningful metric for these purposes, provided that the filing positions a n ticipated from proposed planning are reviewed against the prescribed level of acceptable risk without taking into account any mitigation of the risk factors that are introduced by the planning. Further, the article reviews the evolving tax risk policies of 20 large European companies, showing that while some progress is being made towards meaningful discourse, even the companies with the most well-developed policies are still making their claims in such a way as to conflate socially responsible tax behavior with diligence in implementing antisocial tax behavior.

Otwarty dostęp

Permanent Establishment for Investors in Private Equity Funds—A Legal Analysis in Light of the Changes to the OECD Model (2017)

Data publikacji: 15 Jun 2019
Zakres stron: 16 - 40

Abstrakt

Abstract

The article analyzes whether the investment in a private equity fund may create a permanent establishment (PE) for foreign investors. The analysis is divided into two main parts, as the question of creating a PE for the foreign investors is considered with respect to both the main PE rule and the agency PE rule. The amendments to the PE definition prescribed in the OECD/G20 BEPS report on Action 7, and incorporated into the 2017 version of the OECD Model with Commentary, are taken into consideration. It is concluded that the final outcome depends on the specific setup of the private equity fund at hand and that some degree of uncertainty may often remain. Moreover, the recent amendments to the PE definition do not appear to have reduced this uncertainty—rather the contrary.

Słowa kluczowe

  • Private equity funds
  • international tax law
  • permanent establishment
  • dependent agent
  • BEPS
  • international tax policy
Otwarty dostęp

The Decisive Moment(s or periods) in the Application of Income Tax Rules and the Importance of Events Thereafter – a Swedish, Norwegian and Finnish Perspective and Comparison

Data publikacji: 03 Aug 2019
Zakres stron: 41 - 55

Abstrakt

Abstract

For a correct application of tax laws, it is central to know at what time or period the conditions of each case are to be tested against the respective tax rule. For example, in many questions, the conditions at the time of the transaction are decisive, but not seldom the tax rules take aim at the conditions at the end of the year – or some other time or period. It is also important to know what significance should be given to events after this time or period, not least when the income declaration is made and assessed. Here, these partly overlooked questions are presented and analyzed from the Swedish, Norwegian and Finnish income tax-perspectives.

Otwarty dostęp

Basic Income—an early Icelandic experiment**

Data publikacji: 07 Aug 2019
Zakres stron: 56 - 62

Abstrakt

Abstract

Old age, illness, and/or physical and/or mental disabilities may limit the ability of an individual to generate enough income to cover basic costs of living. Most developed nations provide financial assistance to persons with limited abilities. In 1974, an Icelandic government passed an act of law providing a tax credit, payable to taxpayers under certain conditions. The tax allowance was applied first to settle the taxes and public levies owed by the taxpayer, with any amount remaining paid out to the individual. This system can be seen as a first, limited attempt at establishing a partial universal basic income of sorts. This social interaction between stakeholders on how to share the tax revenue between the taxpayers led to a government crisis. The shareholders in this partial universal basic income system, the state and municipalities, the old age community, the trade unions, and the employers all have different financial and political interests and were affected by this reform. The lesson is that a basic income would need strong supporters if implemented, where the role of the government and/or the parliament would be mapped. Its supporters must be able to withstand the pressure from the social partners in the labor market because of the interactivity of the social security system and the pension fund system, which is not a part of the fiscal system in Iceland. The conflict of interests becomes apparent.

Otwarty dostęp

BEPS Policy Failure—The Case of EU Country-By-Country Reporting1

Data publikacji: 25 Mar 2020
Zakres stron: 63 - 86

Abstrakt

Abstract

The tax gap between taxes that are “actually” paid and taxes that “ought” to have been paid by multinational corporate entities has become an area of huge public policy concern in the recent decades. This study reviews the impact of new legislation to reveal the tax gap created by the EU banks and financial institutions passed in 2013 and in particular of the quality of the resulting country-by-country reporting (CBCR) requirement for banks. Although resulting tax gap estimates are noted, they suffer due to significant problems in the published data; much of it is due to the quality of the regulation requiring its publication and implementation. The findings reveal a lack of understanding of the technical and structural weaknesses of accounting in a transnational context in the design of this regulation. CBCR is destined to fail in achieving its regulatory objectives in this context unless necessary reform of the regulation is undertaken.

Słowa kluczowe

  • Tax gaps
  • Tax avoidance
  • Accounting
  • Policy-making
  • Country-by-country reporting
  • CRD IV
5 Artykułów

Article

Otwarty dostęp

Acceptable levels of tax risk as a metric of corporate tax responsibility: theory, and a survey of practice

Data publikacji: 15 Jun 2019
Zakres stron: 1 - 15

Abstrakt

Abstract

Prescribed levels of acceptable tax risk are increasingly used to articulate degrees of corporate tax responsibility, but the theoretical basis for doing so is not well established. This article (i) develops a theory of the relationship between tax risk and tax responsibility and (ii) shows that acceptable levels of tax risk could be used as a meaningful metric for these purposes, provided that the filing positions a n ticipated from proposed planning are reviewed against the prescribed level of acceptable risk without taking into account any mitigation of the risk factors that are introduced by the planning. Further, the article reviews the evolving tax risk policies of 20 large European companies, showing that while some progress is being made towards meaningful discourse, even the companies with the most well-developed policies are still making their claims in such a way as to conflate socially responsible tax behavior with diligence in implementing antisocial tax behavior.

Otwarty dostęp

Permanent Establishment for Investors in Private Equity Funds—A Legal Analysis in Light of the Changes to the OECD Model (2017)

Data publikacji: 15 Jun 2019
Zakres stron: 16 - 40

Abstrakt

Abstract

The article analyzes whether the investment in a private equity fund may create a permanent establishment (PE) for foreign investors. The analysis is divided into two main parts, as the question of creating a PE for the foreign investors is considered with respect to both the main PE rule and the agency PE rule. The amendments to the PE definition prescribed in the OECD/G20 BEPS report on Action 7, and incorporated into the 2017 version of the OECD Model with Commentary, are taken into consideration. It is concluded that the final outcome depends on the specific setup of the private equity fund at hand and that some degree of uncertainty may often remain. Moreover, the recent amendments to the PE definition do not appear to have reduced this uncertainty—rather the contrary.

Słowa kluczowe

  • Private equity funds
  • international tax law
  • permanent establishment
  • dependent agent
  • BEPS
  • international tax policy
Otwarty dostęp

The Decisive Moment(s or periods) in the Application of Income Tax Rules and the Importance of Events Thereafter – a Swedish, Norwegian and Finnish Perspective and Comparison

Data publikacji: 03 Aug 2019
Zakres stron: 41 - 55

Abstrakt

Abstract

For a correct application of tax laws, it is central to know at what time or period the conditions of each case are to be tested against the respective tax rule. For example, in many questions, the conditions at the time of the transaction are decisive, but not seldom the tax rules take aim at the conditions at the end of the year – or some other time or period. It is also important to know what significance should be given to events after this time or period, not least when the income declaration is made and assessed. Here, these partly overlooked questions are presented and analyzed from the Swedish, Norwegian and Finnish income tax-perspectives.

Otwarty dostęp

Basic Income—an early Icelandic experiment**

Data publikacji: 07 Aug 2019
Zakres stron: 56 - 62

Abstrakt

Abstract

Old age, illness, and/or physical and/or mental disabilities may limit the ability of an individual to generate enough income to cover basic costs of living. Most developed nations provide financial assistance to persons with limited abilities. In 1974, an Icelandic government passed an act of law providing a tax credit, payable to taxpayers under certain conditions. The tax allowance was applied first to settle the taxes and public levies owed by the taxpayer, with any amount remaining paid out to the individual. This system can be seen as a first, limited attempt at establishing a partial universal basic income of sorts. This social interaction between stakeholders on how to share the tax revenue between the taxpayers led to a government crisis. The shareholders in this partial universal basic income system, the state and municipalities, the old age community, the trade unions, and the employers all have different financial and political interests and were affected by this reform. The lesson is that a basic income would need strong supporters if implemented, where the role of the government and/or the parliament would be mapped. Its supporters must be able to withstand the pressure from the social partners in the labor market because of the interactivity of the social security system and the pension fund system, which is not a part of the fiscal system in Iceland. The conflict of interests becomes apparent.

Otwarty dostęp

BEPS Policy Failure—The Case of EU Country-By-Country Reporting1

Data publikacji: 25 Mar 2020
Zakres stron: 63 - 86

Abstrakt

Abstract

The tax gap between taxes that are “actually” paid and taxes that “ought” to have been paid by multinational corporate entities has become an area of huge public policy concern in the recent decades. This study reviews the impact of new legislation to reveal the tax gap created by the EU banks and financial institutions passed in 2013 and in particular of the quality of the resulting country-by-country reporting (CBCR) requirement for banks. Although resulting tax gap estimates are noted, they suffer due to significant problems in the published data; much of it is due to the quality of the regulation requiring its publication and implementation. The findings reveal a lack of understanding of the technical and structural weaknesses of accounting in a transnational context in the design of this regulation. CBCR is destined to fail in achieving its regulatory objectives in this context unless necessary reform of the regulation is undertaken.

Słowa kluczowe

  • Tax gaps
  • Tax avoidance
  • Accounting
  • Policy-making
  • Country-by-country reporting
  • CRD IV

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