This book undertakes a fundamental review of the existing international system of taxing business profit. It steps back from the current political debates on how to combat profit shifting and how taxing rights over the profits of the digitalized economy should be allocated. Instead, it starts from first principles to ask how we should evaluate a tax on business profit--and whether there is any good rationale for such a tax in the first place. It then goes on to evaluate the existing system and a number of alternatives that have been proposed. It argues that the existing system is fundamentally flawed, and that there is a need for radical reform. The key conclusion from the analysis is that there would be significant gains from a reform that moved the system towards taxing profit in the country in which a business made its sales to third parties. That conclusion informs two proposals that are put forward in detail and evaluated: the Residual Profit Allocation by Income (RPAI) and the Destination-based Cash Flow Tax (DBCFT).
The book is authored by group of economists and lawyers--the Oxford International Tax Group, chaired by Michael P. Devereux. It draws insights from both economics and law--including economic theory, empirical evidence on the impact of taxes, and an examination of practical issues of implementation--to assess the existing system and to consider fundamental reforms. This book will be useful to tax policy makers, tax professionals, academics, and anyone interested in tax policy.
Michael P. Devereux, Director of the Oxford University Centre for Business Taxation and Professor of Business Taxation, University of Oxford, Alan J. Auerbach, Robert D. Burch Professor of Economics and Law, University of California, Berkeley, Michael Keen, Deputy Director of the Fiscal Affairs Department, International Monetary Fund, Paul Oosterhuis, Senior International Tax Partner, Skadden, Arps, Slate, Meagher and Flom, Wolfgang Schön, Managing Director, Max Planck Institute for Tax Law and Public Finance, Munich, John Vella, Professor of Law, University of Oxford
Michael P. Devereux is Director of the Oxford University Centre for Business Taxation, Professor of Business Taxation at the Saïd Business School, University of Oxford and Professorial Fellow at Oriel College, Oxford.
Alan J. Auerbach is Robert D. Burch Professor of Economics and Law, and Director of the Burch Center for Tax Policy and Public Finance at the University of California, Berkeley.
Michael Keen is Deputy Director of the Fiscal Affairs Department of the International Monetary Fund.
Paul Oosterhuis is Of Counsel, International Tax in the Washington, DC office of Skadden, Arps, Slate, Meagher & Flom.
Wolfgang Schön is the Managing Director of the Max Planck Institute for Tax Law and Public Finance in Munich and Honorary Professor at Munich University.
John Vella is Professor of Law at the University of Oxford, Assistant Director of the Oxford University Centre for Business Taxation, and a Fellow of Harris Manchester College, Oxford.
