WHERE NEXT FOR CT?

摘要

The tax policy topic of the decade is the OECD's Base Erosion and Profit Shifting (BEPS) project. This retains the long-standing approach to international corporate tax, but refines the approach so as to reduce double non-taxation. However, are there other options? The Mirrlees review considered the different treatment of debt and equity, and opted for an allowance for corporate equity. This allowance is a deemed tax deduction - which either reduces the corporate tax yield or requires that the statutory rate be increased. The report considers the source and residence taxation - and concludes that source-based taxation is preferred. Intriguingly, it asks whether a destination-based tax should be chosen - in other words levying a profit-based tax in the location of the customer.