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The article reviews the development of the international (offshore) banking sector in Cyprus and focuses on the effects of the transitional corporate tax regime, introduced for this sector, since the country’s admission into the European Union. The consolidated performance of international banks and data collected through semi‐structured questionnaires are examined to provide important insights into how management perceives of the new tax regime and of its impact upon the country’s attractiveness as an international banking center.

Both, the UK and Japan abolished the tax credit system for foreign source dividends in 2009 in favour of the exemption system. With the move towards a dividend exemption system the governments intended to enhance the international tax competitiveness of their countries. The purpose of this paper is to evaluate the implications of substituting the credit system for the exemption system in the UK and Japan on cross-border transaction prices when competing for international acquisitions.

The paper uses an economic model under certainty to analyse the changes in cross-border marginal purchase and seller prices as a result of the introduction of the newly introduced dividend exemption system.

Shifting to an exemption system has ambiguous effects on the ability to compete for foreign acquisitions: investors from both countries are able to pay higher prices in the course of acquisitions, but while investors from the UK become more competitive, the relative competitive position for Japanese investors hardly changes and remains relatively constrained, independent of the form of double taxation relief. Thus the author verifies that the international tax regime is not the only determinant influencing the competitive position, ranking second to, e.g., the interaction with international tax rate differentials.

The international tax reforms in UK and Japan in 2009 offer a unique opportunity to study the impact of international tax policy on the international tax competitiveness of multinational firms in the course of foreign acquisitions. Evidence from this paper is not exclusively applicable to the UK and Japan setting. The observed effects shed new light on the intensified debate in the USA of changing the international tax system by analysing the impact on the bidding situation in international acquisitions in a real-world transition scenario.

Accounting programs and tax course offerings have been evolving in recent years, and one concern is the coverage of international tax topics. Although international tax is of prime importance to multinational corporations and Congress, little research has addressed the extent to which accounting programs cover international tax topics and whether demand for such coverage exists. This chapter presents the results of surveys about how students desiring a career in international tax services (ITS) can obtain international tax knowledge and what topical areas are most important. Many graduate accounting and taxation programs offer stand-alone international tax courses. Recruiters and professors characterize foreign tax credits, transfer pricing and treaties as the most important areas to emphasize in these courses. Though not essential to a career in ITS, taking an international tax course while in school exposes the student to this career opportunity, and a significant percentage of new hires come from programs offering such a course. Our results provide accounting educators with information to evaluate their coverage of international tax topics, and to make changes if needed.

This paper aims to understand the international practices of tax planning. International companies choose their capital structure according to differences in international taxation, in order to minimize the tax burden of the whole company group. This paper reviews the literature that deals with international tax avoidance techniques by highlighting tax planning measurements in the empirical literature. The methodology used is the narrative approach of literature review, which consists on assembling and synthesizing previously published research. The paper concludes that there are several approaches of international tax planning including transfers of revenues by geographical area, redevelopment of the company, haven and loopholes in tax legislation. Moreover, finding more precise measures of tax planning techniques would be of great value to studies in this respect.

The authors follow the guideline provided by Templier and Pare (2015) in order to select the type of the literature review to use in this paper. Accordingly, this paper employs the narrative approach of literature review, which consists on assembling and synthesizing previously published research on international tax planning. This narrative review will serve as a starting point for future investigations and research developments. The authors rely on a logic of configuration in order to analyze data. This logic consists on addressing then organizing various aspects of international practices of tax planning.

The paper concludes that there are many aspects of international tax planning that need to be covered by future researchers, especially finding more precise measures of tax planning techniques would be of great value to studies in this respect.

The literature survey reveals the following issues. First, few studies have been conducted to date. Second, several approaches remain unexplored, and studies rely only on surveys' results collected from the annual report of companies (microeconomics variables), while macroeconomic variables can better explain the phenomenon of international tax planning. In this context, studies containing proposals to estimate more accurate international companies' tax planning techniques would also be welcome. Previous literature supposes premises on this issue th:at limit the accurateness of the analysis. Particularly, empirical literature is short of the proper measurement to evaluate corporate tax avoidance. This would explain the various interpretations of research findings. Hence, finding more precise measures of tax planning techniques would be of great value to studies in this respect.

This literature survey highlights recent studies dealing with tax planning theories within the framework of corporate governance. This theoretical framework particularly specifies which key variables are the most suitable for measuring tax planning methods and highlights the need to examine how those key variables might differ and under what circumstances. In addition, it underlines limits on tax planning measurements by addressing the comparison of the empirical measurements.

The paper contributes to the literature on internal tax planning in several ways. First, this study is unique in that it constitutes the only literature review that provides a comprehensive overview of research on international tax planning. Especially, it extends previous studies by considering the specific new trend of empirical literature dealing with the techniques of international tax planning. This literature review identifies two categories of tax planning approaches including techniques related to company internal management practices and international tax planning techniques. In addition, the literature survey helps to determine various strategies used by multinationals for tax planning, through an in-depth review of the existing studies. Finally, it provides researchers with a starting point to further explore issues related to tax avoidance techniques.

This paper aims to investigate empirically how international tourism receipts influence public revenue, in particular non-resource revenue.

The analysis relies on an unbalanced panel of 156 countries (including both developed and developing countries) over the period 1995-2015. The empirical analysis uses the two-step system generalized methods of moments estimator.

The empirical results show that international tourism receipts exert a positive and significant impact on non-resource tax revenue. In addition, this effect increases as countries' development levels rise, which signifies that in terms of non-resource tax revenue, an increase in international tourism receipts benefit much more to advanced economies than to less advanced economies.

These findings call for governments notably in developing countries to develop the tourism sector and concurrently to strengthen tax administrations (and possibly design appropriate tax policy for the tourism sector) to derive the full advantage in terms of public revenue from the rise in international tourism receipts.

The analysis highlights the importance of international tourism receipts for public revenue. This would help scholars and policymakers have a clearer view, at least in terms of magnitude, on the impact of international tourism receipts on non-resource tax revenue.

To the best of the author’s knowledge, this is first the study that investigates this topic.

本文就国际旅游收入如何影响公共收入尤其是非资源收入的问题, 进行了实证研究。

本文的分析基于1995年至2015年期间由156个国家（包括发达国家和发展中国家）组成的不平衡小组的数据。 实证分析采用两步法通用矩量法（GMM）估计。

实证结果表明, 国际旅游收入对非资源税收入产生了积极而显著的影响。 而且, 这种影响随着国家发展水平的提高而增加, 这表明就非资源税收入而言, 国际旅游收入的增加对发达经济体的收益要比对较不发达经济体的收益大得多。

结果表明, 各国政府尤其是发展中国家的政府, 应当发展旅游业, 同时加强税收管理（并可能为旅游业设计适当的税收政策）, 以便从国际旅游业的增长中获得公共收入方面的最大收益。

分析强调了国际旅游收入对公共收入的重要性。 这将有助于学者和决策者对国际旅游收入对非资源税收入的影响（至少在规模上）有更清晰的认识。

据我们所知, 本文是第一个研究该主题的研究。

旅游外汇收入，非资源性收入

研究论文

El artículo investiga empíricamente, cómo los ingresos internacionales por turismo influyen en los ingresos públicos, en particular, todos aquellos ingresos “no relacionados” con los recursos turísticos.

El análisis se basa en un panel no-equilibrado de 156 países (incluidos países desarrollados y en desarrollo) durante el período 1995-2015. El análisis empírico que se aplica, se fundamente en dos fases sobre el estimador de Métodos Generalizados de Momentos (GMM).

Los resultados muestran que los ingresos internacionales por turismo, ejercen un impacto positivo y significativo, en los ingresos fiscales no relacionados con los recursos turísticos. Además, este efecto aumenta, a medida que aumentan los niveles de desarrollo de los países, lo que significa que, en términos de ingresos fiscales, no relacionados con los recursos, un aumento en los ingresos internacionales por turismo, beneficia mucho más a las economías avanzadas, que a las economías menos avanzadas.

Los descubrimientos de este trabajo, exigen que los gobiernos, en particular en los países en desarrollo, fomenten el sector turístico y al mismo tiempo, fortalezcan las administraciones tributarias (y posiblemente diseñen una política fiscal adecuada para el sector turístico), con el fin de obtener una ventaja total, en términos de ingresos públicos por el aumento de los ingresos del turismo internacional.

El análisis destaca la importancia de los ingresos por el turismo internacional en los ingresos públicos. Esto ayudaría a los académicos y gestores de políticas a tener una visión más clara, al menos en términos de magnitud, sobre el impacto de los ingresos por el turismo internacional en los ingresos fiscales no relacionados con los recursos turísticos.

Hasta donde sabemos, este es primero el estudio que investiga este tema.

Recibos de turismo internacional, Ingresos no recurrentes

Trabajo de investigación

The purpose of this paper is, first, to discuss if the Portuguese corporate tax reform, implemented in 2014, moved the system towards international trends. Second is to analyse in what areas the similarities and disparities are more pronounced when assessing the Portuguese reform against the Common Consolidated Corporate Tax Base, the Mirrlees Review or other relevant international guidelines. Finally, it assesses how a European country under a bailout could significantly reform the corporate tax.

The methodology employed is based on a mix of the legal research method and case study analysis. The legal method will be applied under comparative income taxation, and the case study will draw on the Portuguese reform to broaden the discussion about critical issues like the participation exemption regime and its place in the taxation of international income flows. The paper will analyse core issues in international income taxation, the present state of corporate tax harmonization in the European Union, discuss the main issues that were dealt by the Portuguese tax reform and offer a critical assessment of tax policy choices that underpinned the reform.

During the past decades, Portugal was increasingly out of line with international trends in corporate taxation. The bailout asked for the Portuguese Government in 2011 placed a heavy burden in public finances, with an apparent lack of room to follow international trends of corporate tax reform. However, it can be concluded that, after convincing the troika that investment and growth were paramount to overcome the severe economic and social crisis that fell upon the country, the corporate tax was seen as an important policy tool to promote these goals. The reform was thus possible even in the context of a restrictive public finance situation, and followed most guidelines put forward in highly regarded international reports.

A broad corporate tax reform, including rate reduction, a participation exemption regime, a more flexible rule on cost acceptance, an extension of loss carry over period, to name a few, was possible in a very constrained public finance situation. By placing the emphasis on moving the system towards international trends and promoting measures to enhance investment and growth, international creditors could accept such a reform. Also, a consensus with the main opposition party was a very important factor in securing much needed political support.

The findings from what can be considered as an experiment in corporate tax reform in tough economic and social times can be useful to policymakers, tax authorities and international bodies dealing with tax reform processes. The impact on managerial decisions such as investment and financing is also relevant.

The purpose of this paper is to unveil the true background of the Base Erosion and Profit Shifting (BEPS) Project and to suggest crucial indexes for bringing a movement into a future ceiling causing a struggle of the international tax system.

This paper looks into the historical context of this project before and after Starbucks’ scandal, comparing to other contexts of the international tax system. Also, this paper partially reviews BEPS from a legal perspective.

The key factors for building momentum of reform of international taxation are a country having a government willing to embrace the cause of reform, unfairness felt toward entities using tax avoidance schemes which other comparable entities could not be use, grass-roots pressure for the reform, effective places to negotiate cooperation among major countries for the reform, solid cooperation among many countries in the world to implement standards and rhetoric of slogan with less opposition.

The momentum of the reform of international taxation was analyzed before. But the BEPS Project has involved some unique events as compared with the Organization for Economic Cooperation and Development’s project on harmful tax practices, such as initiation of NGOs and boycott by consumers. Additionally, this paper will discuss insights, which the former research did not do.

This paper aims to discuss the tax-related illicit financial flows from a human rights perspective. It argues that curbing illicit financial flows, and specifically tax abuse, is essential not only for realizing human rights but also for achieving the sustainable development goals. It provides definitions of tax evasion and avoidance, as well as estimations of illicit financial flows. It studies the tax abuse implications for human rights and sustainable development, as well as the obligations in the field of human rights and tax abuse. It also critically assesses the recent international initiatives aim at curbing illicit financial flows. It concludes with a set of recommendations on how to curb illicit financial flows.

This paper combines economic, legal and policy perspectives to study the multidimensional, complex and global problem of illicit financial flows. It not only proposes an explanation of the volume, roots and economic, social and human rights implications of illicit financial flows but it also proposes reforms that states and other stakeholders need to implement in order to curb this phenomenon.

Combating tax abuse and illicit financial flows more broadly, is essential to make better progress in realizing international human rights obligations. The inclusion of a specific target to reduce illicit financial flows under the sustainable development goals makes clear that curbing such flows is also essential for creating an enabling environment for sustainable development. While we should applaud that reducing illicit financial flows is mentioned in one of the targets of the sustainable development goals, the target remains broad and vague. Specific measures to operationalize this target are needed to ensure that progress is achieved and that such progress can be tracked and measured. The author presents recommendations for discussion. To promote accountability, the recommendations are addressed to specific stakeholders.

This paper tries to contribute to improve our knowledge and understanding of illicit financial flows and tax abuse more specifically at global level and their implications for human rights, to make the need for change more compelling, as well as to stimulate the debate around reforms that need to be implemented to curb illicit financial flows.

The purpose of this chapter is to serve as a resource for accounting faculty seeking tax-related cases to include in their courses. This annotated bibliography provides a table and discussion of 50 educational tax cases published in six major accounting journals from 2003 to 2021. Cases are classified and discussed by recommended course placement. In addition, the authors make observations about trends in case content and format. This chapter complements the Fogarty (2022) review and commentary on tax cases published in this volume.

We examine the stock market reaction to the Tax Cuts and Jobs Act (TCJA) of 2017 during its enactment process, focusing on its international provisions. Consistent with extant evidence, we find lower returns for high-foreign-activity firms, indicating a negative market reaction to the international provisions overall. Considering specific international provisions, we find that the market reaction was more positive (negative) for firms likely most affected by the shift to a quasi-territorial system for taxing foreign earnings (the transition tax on existing unrepatriated earnings, the tax on global intangible low-taxed income, and/or the base erosion and antiabuse tax) than for other firms. Our findings imply that investors are able to disentangle the economic implications of complex and interactive tax law changes.