INTERNATIONAL TAX PLANNING UNDER THE DESTINATION-BASED CASH FLOW TAX

Alan J. Auerbach · Michael Devereux · Michael Keen · John Vella

64 citations0/0 files storedNational Tax Journal

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Corporate Taxation and Avoidance Economic and Fiscal Studies Taxation and Legal Issues

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.

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References

2010Dimensions of tax design: the Mirrlees review 2015THE EFFECT OF PROFIT SHIFTING ON THE CORPORATE TAX BASE IN THE UNITED STATES AND BEYOND 2016Base Erosion, Profit Shifting and Developing Countries 2007Taxing Corporate Income 2017Transfer Pricing and the Arm's Length Principle After BEPS

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