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ISBN Number: 978-92-64-03811-0
Publication Date: 16/11/2007
Pages:131
Number of tables: 4
Number of graphs: 16
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OECD Tax Policy Studies 16: Fundamental Reform of Corporate Income Tax
This report presents the recent trends in the taxation of corporate income in OECD countries and discusses the main drivers of corporate income tax reform and evaluates the gains of fundamental corporate tax refom. The corporate tax-induced distortions are discussed from a domestic and international tax point of view. This study also considers tax revenue and tax complexity issues.
Countries can fundamentally reform their corporate income tax systems in different ways. Governments might implement a full imputation tax system, a corporate allowance for corporate equity (or capital) tax system, a shareholder allowance/credit for corporate equity tax system, an allowance for shareholder equity tax system or a comprehensive business income tax system. Or, instead of taxing corporate income, governments might implement a corporate cash-flow tax. In that case, countries might implement a destination-based corporate cash-flow tax or an origin-based corporate cash-flow tax (the Hall-Rabushka flat tax, the Bradford X-tax, and Zodrow and Mc Lure’s two-tier progressive rate cash-flow tax). These fundamental corporate tax reform proposals are discussed in detail.
Other titles in the series of tax policy studies
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Example Tables
Table 1.2. Statutory corporate income tax rate: 1982-2006*

* Data for 1982 was only available for 17 OECD countries (Japan, the US, Germany, Italy, Spain, France, Belgium, Australia, the UK, the Netherlands, Greece, Norway, Sweden, Portugal, Finland, Austria and Ireland). In the case of Ireland, there was a reduced corporate tax rate of 10 per cent for the manufacturing sector in 1982 and 1994.
Source: Institute for Fiscal Studies (IFS) and OECD Tax Database.
Table 1.4. Overall statutory tax rate on dividend income in 2000 and 2006*

* For each country, the first column presents the data for 2000; the second column presents the data for 2006.
Source: OECD Tax Database
Table 1.12. Taxes on corporate income as a percentage of GDP
Unweighted OECD average over time

Efficiency under fundamentally reformed corporate tax systems

(1): only the host country's corporate tax rate is considered
D = distorted; N = neutral; P = possibly neutral
ACE = allowance for corporate equity tax system;
ACC = allowance for corporate capital tax system;
ASE = allowance for shareholder equity tax system;
Shareholder ACE = shareholder allowance for corporate equity tax system
CIT = corporate income tax;
CBIT = comprehensive business income tax;
PCIT = presumptive capital income tax
Executive Summary
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Table of contents
Executive Summary
Chapter 1. Trends in the Taxation of Corporate Income in OECD Countries
1.1. Statutory corporate tax rates 1982-2006
1.2. Central and sub-central government corporate income tax rate
1.3. Statutory corporate income tax rates accross different-sized countries and accross regions
1.4. Top tax rate on dividend income
1.5. Corporate tax base
1.6. Marginal effective tax rates
1.7. Average effective tax rates
1.8. Corporate tax revenues as a percentage of GDP
1.9. Corporate tax revenues as a percentage of total tax revenue
1.10. Lower tax burdens but no decrease in corporate tax revenues
1.11. Implications for the future
Chapter 2. Why Levy a Corporate Income Tax ?
2.1. Reasons for taxing capital income
2.2. Reasons for taxing corporate income
2.3. Taxing capital income at the corporate or personal level
Chapter 3. Fundamental Corporate Income versus Consumption Type of TAx Reform
3.1. Different types of accounting systems
3.2. Corporate income versus consumption type of tax reform
Chapter 4. The Main Drivers of Corporate Income Tax Reform in OECD Countries
4.1. Domestic efficiency considerations
4.2. International efficiency considerations
4.3. Tax incidence considerations
4.4. Tax revenue considerations
4.5. Tax complexity considerations
Chapter 5. Integration of Corporate Income and Personal Tax Income Taxation
5.1. Full integration
5.2. Dual income tax DIT system
5.3. Allowance for corporate equity ACE tax system
5.4. Allowance for shareholder equity ASE tax system
5.5. Comprehensive business income tax CBIT
5.6. Methods for integration of distributed profits alone
Chapter 6. Corporate Cash-flow Taxation
6.1. The cash-flow corporate tax base
6.2. Efficiency considerations at the corporate level
6.3. Efficiency considerations with corporate and personal level taxation
6.4. Tax revenue considerations
6.5. Tax complexity and tax avoidance /evasion considerations
6.6. Financial services/sector in the corporate cash-flow tax
6.7. Transitional issues when replacing the corporate income tax with a corporate cash-flow tax
Chapter 7. Corporate Cash-flow Tax Issues in an International Context
7.1. Origin versus destination-based corporate cash-flow taxes
7.2. Destination-based corporate cash-flow tax
7.3. Origin-based corporate cash-flow tax
7.4. Transfer pricing issues
Chapter 8. Corporate Cash-flow Tax Experiences
8.1. The UK North Sea Fiscal Regime
8.2. The petroleum tax system in Norway
8.3. The regional tax on business activities in Italy
8.4. Estonian corporate cash-flow tax
Chapter 9. Fundamental Corporate Tax Reform in Detail
9.1. Full integration tax system
9.2 The allowance for corporate equity tax system
9.3. The allowance for shareholder equity tax system
9.4. The shareholder allowance for corporate equity tax system
9.5. The comprehensive business income tax system
9.6. Destination-based corporate cash-flow tax
9.7. Origin-based corporate cash-flow tax
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