Taxation and Value Creation

Taxation and Value Creation
This book examines whether the concept of value creation is a viable criterion for the allocation of taxing rights under a modernized international tax framework.

Why this book?

The suggestion to “align international taxation with value creation” first emerged in the context of the OECD BEPS Project aimed at tackling aggressive tax planning strategies resulting in base erosion and profit shifting. The concept of “value creation” was then further relied on in the broader discussion that followed about the impact of digitalization on the global economy generally and the fair allocation of taxes between countries in this new environment. Although the idea – or the guiding principle – that profits should be taxed where economic activities occur and where value is expected to be created initially received a relatively large support, it rapidly became clear (at least to academics) that there would be no obvious answer to the question “where is value being created?” in a manner that would be relevant for (international) tax purposes, inter alia in view of the different models of value creation within corporate entities.

Based on 9 thematic reports (offering an interdisciplinary discussion of the concept of value creation mostly from an international perspective) and on 23 national reports (focusing on the meaning of value creation in domestic tax law), this book seeks to contribute to the discussion on whether the concept of value creation is viable, both theoretically and in practice, as a criterion for the allocation of taxing rights under a modernized international tax framework.


Sample excerpt, including table of contents

This book is part of the EATLP International Tax Series

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Hrvoje Arbutina, Gabriel Bez Batti, Radim Boháč, Irene J.J. Burgers, Divesh Chawla, Richard Collier, Katja Dyppel Weber, Eva Escribano, Emrah Ferhatoğlu, Louise Fjord Kjærsgaard, Clemens Fuest, Stefanie Geringer, Danylo Getmantsev, Henrik Guldhammer Nielsen, Werner Haslehner, Sabine Kirchmayr, Dániel Máté Kovács, Marie Lamensch, Amy Lawton, Timo Lemm, Na Li, Emmanuel Llinares, Enguerrand Marique, Ralph Meghames, Jérôme Monsenego, Aitor Navarro, Rachel O’Connor, Shu-Yi Oei, Karl Pauwels, Katerina Perrou, Cees Peters, Michal Radvan, Ronald Russo, Patrick Schmid, Wolfgang Schön, Luís Eduardo Schoueri, Doğan Şenyüz, István Simon, Claus Staringer, Alain Steichen, Dario Stevanato, Raoul Stocker, Zsolt Szatmári, Timo Torkkel, Matthias Valta, Nicolas Vergnet, Petr Vodák, Bjorn Westberg, Güneş Yılmaz, Nataša Žunić Kovačević.

Taxation and Value Creation
Chapter 1: General Report on Value Creation and Taxation: Outlining the Debate
Chapter 2: Value Creation and Income Taxation: A Coherent Framework for Reform?
Chapter 3: Value Creation and VAT
Chapter 4: Taxation in the Place of Value Creation: An Economic Perspective
Chapter 5: Value Creation and Transfer Pricing
Chapter 6: The Value Creation Mythology
Chapter 7: Value Creation, the Benefit Principle and Efficiency-Related Allocation of Taxing Rights
Chapter 8: Value Creation and Inter-Nation Equity
Chapter 9: Value Chain Analysis: An Analytical Tool to Evaluate Economic Contribution in the Overall Framework of Value Creation
Chapter 10: Value Creation and Exit Taxes
Chapter 11: Austria
Chapter 12: Belgium
Chapter 13: Brazil
Chapter 14: China (People’s Rep.)
Chapter 15: Croatia
Chapter 16: Czech Republic
Chapter 17: Denmark
Chapter 18: Finland
Chapter 19: France
Chapter 20: Germany
Chapter 21: Greece
Chapter 22: Hungary
Chapter 23: India
Chapter 24: Italy
Chapter 25: Luxembourg
Chapter 26: The Netherlands
Chapter 27: Spain
Chapter 28: Sweden
Chapter 29: Switzerland
Chapter 30: Turkey
Chapter 31: Ukraine
Chapter 32: United Kingdom
Chapter 33: United States
Appendix: Questionnaire for National Reports

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