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Reform and Coordination of Company Taxes in the European Union

  • Sijbren Cnossen

Abstract

In 1992, the Ruding Committee (1992), appointed by the European Commission to examine the need for company tax (CT) harmonization in the European Union (EU), presented its findings and recommendations.1 Although the Committee concluded that differences in CTs distort the workings of the internal market — differences which most likely would not be eliminated by market forces or tax competition — it nonetheless proposed to leave the CTs in the EU essentially the same as it had found them, replete with their widely diverging domestic and cross-border treatment of different kinds of returns and different kinds of recipients of the various returns. As argued below, however, differential treatment will perpetuate the distortions inherent in the current CTs and erode the taxing authority of source states. A minimum statutory CT rate of 30 per cent, proposed by the Ruding Committee, and the adoption of the (draft) directives of the European Commission2 are insufficient to repair the infringements of the neutrality and subsidiarity requirements, as applied to taxation, agreed to by the member states. More fundamental reform seems called for. Moreover, CT reform in the member states is a condition for CT coordination between the member states.

Keywords

European Union Capital Income Capital Gain Dividend Income Imputation System 
These keywords were added by machine and not by the authors. This process is experimental and the keywords may be updated as the learning algorithm improves.

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References

  1. Andersson, K. and L. Mutén (1994) ‘The Tax System of Sweden’, Tax Notes International, 10 October, pp. 1147–63.Google Scholar
  2. Andrews, W.D. (1979) ALI Federal Income Tax Project, Tentative Draft No. 2, Subchapter C — Corporate Distributions (Philadelphia, Penn.: American Law Institute).Google Scholar
  3. Andrews, W.D. (1989) ALI Federal Income Tax Project, Reporter’s Study Draft — Subchapter C (Supplemental Study) (Philadelphia, Penn.: American Law Institute).Google Scholar
  4. Atkinson, A. B. and A. Sandmo (1980) ‘Welfare Implications of the Taxation of Savings’, Economic Journal, vol. 90, pp. 529–49.CrossRefGoogle Scholar
  5. Bird, R.M. and C.E. McLure Jr. (1990) ‘The Personal Income Tax in an Interdependent World’, in S. Cnossen (ed.), The Personal Income Tax: Phoenix from the Ashes? (Amsterdam: North-Holland).Google Scholar
  6. Boadway, R. and N. Bruce (1984) ‘A General Proposition on the Design of a Neutral Business Tax’, Journal of Public Economics, vol. 24, pp. 231–9.CrossRefGoogle Scholar
  7. Boadway, R. and N. Bruce and J. Mintz (1982) ‘Corporate Taxation in Canada: Toward an Efficient System’, in W.R. Thirsk and J. Whalley (eds). Tax Policy Options in the 1980s (Toronto: Canadian Tax Foundation).Google Scholar
  8. Bond, S.R. and M. Devereux (1995) ‘On the Design of a Neutral Business Tax under Uncertainty’, Journal of Public Economics, vol. 58, pp. 57–91.CrossRefGoogle Scholar
  9. Bradford, D.F. (1986) Untangling the Income Tax (Cambridge: Harvard University Press).CrossRefGoogle Scholar
  10. Brean, D.J.S. (1992) ‘Here or There? The Source and Residence Principles of International Taxation’, in R.M. Bird and J.M. Mintz (eds), Taxation to 2000 and Beyond (Toronto: Canadian Tax Foundation).Google Scholar
  11. Campbell Committee (1981) Final Report of the Committee of Inquiry into the Australian Financial System (Canberra: Australian Government Publishing Service).Google Scholar
  12. Cnossen, S. (1990) ‘The Case for Tax Diversity in the European Community’, European Economic Review, vol. 4, pp. 471–9.CrossRefGoogle Scholar
  13. Cnossen, S. (1995) ‘Towards a New Tax Covenant’, De Economist, vol. 143, pp. 285–315.CrossRefGoogle Scholar
  14. Cnossen, S. and L. Bovenberg (1997) ‘Company Tax Harmonization in the European Union: Some Further Thoughts on the Ruding Committee Report’, in M.I. Blejer and T. Ter-Minassian (eds), Macroeconomic Dimensions of Public Finance: Essays in Honour of Vito Tanzi (London: Routledge).Google Scholar
  15. Daly, M. and J. Weiner (1993) ‘Corporate Tax Harmonization and Competition in Federal Countries: Some Lessons for the European Community’, National Tax Journal, vol. 46, pp. 441–61.Google Scholar
  16. Devereux, M. (1992) ‘The Ruding Committee Report: An Economic Assessment’, Fiscal Studies, vol. 13, no. 2, pp. 96–107.CrossRefGoogle Scholar
  17. Devereux, M. and H. Freeman (1991) ‘A General Neutral Profits Tax’, Fiscal Studies, vol. 12, no. 3, pp. 1–15.CrossRefGoogle Scholar
  18. Devereux, M. and H. Freeman and M. Pearson (1990) ‘Harmonising Corporate Taxes in Europe’, Fiscal Studies, vol. 11, no. 1, pp. 21–35.CrossRefGoogle Scholar
  19. Easson, A. (1992) ‘Harmonization of Direct Taxation in the European Community: From Neumark to Ruding’, Canadian Tax Journal, vol. 40, pp. 600–38.Google Scholar
  20. Easterbrook, F.H. (1984) ‘Two Agency-Cost Explanations of Dividends’, American Economic Review, vol. 74, pp. 650–9.Google Scholar
  21. European Commission (1989) Proposal for a Council Directive on a Common System of Withholding Tax on Interest Income, COM (89) 60/3/Revision final (Brussels).Google Scholar
  22. European Commission (1996), Taxation in the European Union, Discussion Paper for the Informal Meeting of ECOFIN Ministers, SEC (96) 487 final (Brussels).Google Scholar
  23. Fullerton, D. (1986) ‘The Use of Effective Tax Rates in Tax Policy’, National Tax Journal, vol. 39, pp. 285–92.Google Scholar
  24. Gammie, M. (1992a) ‘The Harmonisation of Corporate Income Taxes in Europe: The Ruding Committee Report’, Fiscal Studies, vol. 13, no. 2, pp. 108–21.CrossRefGoogle Scholar
  25. Gammie, M. (1992b) ‘Corporate Tax Harmonisation: An “ACE” proposal’, European Taxation, vol. 31, pp. 238–42.Google Scholar
  26. Gammie, M. (1992c) ‘Reforming Corporate Taxation: An Evaluation of the United States Treasury Integration Proposals and other Corporate Tax Systems in an International Context’, Parts 1 and 2, British Tax Review, nos 3 and 4, pp. 148–73 and 243–76.Google Scholar
  27. Gerardi, G., M.J. Graetz and H.S. Rosen (1990) ‘Corporate Integration Puzzles’, National Tax Journal, vol. 43, pp. 307–14.Google Scholar
  28. Goode, R. (1975) The Individual Income Tax, 2nd edn (Washington, DC: Brookings Institution).Google Scholar
  29. Goode, R. (1992) ‘Integration of Corporate and Individual Taxes: A Treasury Report’, Tax Notes (Special Report), 30 March, pp. 1667–71.Google Scholar
  30. Gordon, R.H. and J. Slemrod (1988), ‘Do We Collect Any Revenue from Taxing Capital Income?’, in L.H. Summers (ed.), Tax Policy and the Economy, vol. 2 (Cambridge, Mass.: MIT Press).Google Scholar
  31. Graetz, M.J. (1989) ‘The Tax Aspects of Leveraged Buyouts and Other Corporate Financial Restructuring Transactions’, Tax Notes, 6 February, pp. 721–6.Google Scholar
  32. Gravelle, J.G. (1994) The Economic Effects of Taxing Capital Income (Cambridge, Mass.: MIT Press).Google Scholar
  33. Gravelle, J.G. and L.J. Kotlikoff (1989) ‘The Incidence and Efficiency Costs of Corporate Taxation When Corporate and Noncorporate Firms Produce the Same Good’, Journal of Political Economy, vol. 97, pp. 749–90.CrossRefGoogle Scholar
  34. Grosskopf, G. (1990) ‘The Swedish Tax Reform: Rules and Effects’, Bulletin for International Fiscal Documentation, August/September, pp. 366–85.Google Scholar
  35. Hagen, K.P. and P.B. Sørensen (forthcoming) ‘Taxation of the Self-Employed: Taxation Principles and Tax Reforms in Scandinavia’, in P.B. S0rensen (ed.), Tax Policy in the Nordic Countries.Google Scholar
  36. Hall, R.E. and A. Rabushka (1995) The Flat Rate, 2nd edn (Stanford, Calif.: Hoover Institution Press).Google Scholar
  37. Head, J.G. (1997) ‘Company Tax Structure and Company Tax Incidence’, International Tax and Public Finance, vol. 4, pp. 61–99.CrossRefGoogle Scholar
  38. Huizinga, H. (1994) ‘International Interest Withholding Taxation: Prospects for a Common European Policy’, International Tax and Public Finance, vol. 1, pp. 277–91.CrossRefGoogle Scholar
  39. IFS Capital Taxes Group (1989) Neutrality in the Taxation of Savings: An Extended Role for PEPs, Commentary No. 17 (London: Institute for Fiscal Studies).Google Scholar
  40. IFS Capital Taxes Group (1991) Equity for Companies: A Corporation Tax for the 1990s, Commentary No. 26 (London: Institute for Fiscal Studies).Google Scholar
  41. Keen, M. (1994) ‘The Welfare Economics of Tax Co-ordination in the European Community: A Survey’, Fiscal Studies, vol. 14, no. 2, pp. 15–36.CrossRefGoogle Scholar
  42. King, M.A. (1980) ‘Saving and Taxation’, in G.A. Hughes and G.M. Heal (eds), Public Policy and the Tax System (London: Allen & Unwin).Google Scholar
  43. Kopits, G. (ed.) (1992) Tax Harmonization in the European Community: Policy Issues and Analysis, IMF Occasional Papers No. 94 (Washington, DC: International Monetary Fund).Google Scholar
  44. Lockwood, B. and A. Manning (1993) ‘Wage Setting and the Tax System: Theory and Evidence from the United Kingdom’, Journal of Public Economics, vol. 52, pp. 1–29.CrossRefGoogle Scholar
  45. Lodin, S.-O. (1993) The Nordic Reforms of Company and Shareholder Taxation (Federation of Swedish Industries).Google Scholar
  46. McLure, C.E., Jr (1979) Must Corporate Income Be Taxed Twice? (Washington, DC: Brookings Institution).Google Scholar
  47. McLure, C.E., Jr (1989) ‘Economic Integration and European Taxation of Corporate Income at Source: Some Lessons from the U.S. Experience’, European Taxation, vol. 29, August, pp. 243–50.Google Scholar
  48. McLure, C.E., Jr (1992a) ‘Coordinating Business Taxation in the Single European Market: The Ruding Committee Report’, EC Tax Review, vol. 1, pp. 13–20.Google Scholar
  49. McLure, C.E., Jr (1992b) ‘Substituting Consumption-based Direct Taxation for Income Taxes as the International Norm’, National Tax Journal, vol. 45, pp. 145–54.Google Scholar
  50. McLure, C.E. and G.R. Zodrow (1996) ‘A Hybrid Consumption-based Direct Tax for Bolivia’, International Tax and Public Finance, vol. 3, pp. 97–112.CrossRefGoogle Scholar
  51. Meade Committee (1978) The Structure and Reform of Direct Taxation (London: Institute for Fiscal Studies).Google Scholar
  52. Mintz, J. (1995) ‘The Corporation Tax: A Survey’, Fiscal Studies, vol. 16, no. 4, pp. 23–68.CrossRefGoogle Scholar
  53. Mintz, J. and J. Seade (1991) ‘Cash Flow or Income? The Choice of Base for Company Taxation’, The World Bank Research Observer, vol. 6, pp. 177–90.CrossRefGoogle Scholar
  54. Musgrave, P.B. (1987) ‘Interjurisdictional Coordination of Taxes on Capital Income’, in S. Cnossen (ed.), Tax Coordination in the European Community (Deventer: Kluwer).Google Scholar
  55. Musgrave, R.A. and P.B. Musgrave (1984) Public Finance in Theory and Practice, 4th edn (New York: McGraw-Hill).Google Scholar
  56. Mutén, L. (1992) ‘The Fiscal Revolution in Sweden — Tax Reform in Preparation for European Integration’, Tax Notes International, 16 November, pp. 1045–52.Google Scholar
  57. OECD (1974) ‘Report on Taxation of Loan Capital’, unpublished (Paris).Google Scholar
  58. OECD (1991) Taxing Profits in a Global Economy: Domestic and International Issues (Paris: Organisation for Economic Cooperation and Development).Google Scholar
  59. OECD (1994) Revenue Statistics in OECD Member Countries 1965–1993 (Paris: Organisation for Economic Cooperation and Development).Google Scholar
  60. Owens, J. (1993) ‘Globalisation: The Implications for Tax Policies’, Fiscal Studies, vol. 14, no. 3, pp. 21–44.CrossRefGoogle Scholar
  61. Pedersen, B.M. (1993) ‘Denmark: Tax Reform’, Bulletin for International Fiscal Documentation, December, pp. 711–15.Google Scholar
  62. Poterba, J.M. (1987) ‘Tax Policy and Corporate Saving’, Brookings Papers on Economic Activity, vol. 2, pp. 455–515.CrossRefGoogle Scholar
  63. Poterba, J.M., and L.H. Summers (1985) ‘The Economic Effects of Dividend Taxation’, in E. Altman and M. Subrahmanyam (eds), Recent Advances in Corporate Finance (Homewood, Ill.: Irwin).Google Scholar
  64. Razin, A. and E. Sadka (1989) ‘International Tax Competition and Gains from Tax Harmonization’, National Bureau of Economic Research, Working Paper No. 3152.Google Scholar
  65. Rose, M. and R. Wiswesser (this volume) ‘Tax Reform in Transition Economies: Experiences from the Croatian Tax Reform Process of the 1990s’.Google Scholar
  66. Royal (Carter) Commission on Taxation (1966) Report (Ottawa: Queen’s Printer).Google Scholar
  67. Ruding Committee (1992) Conclusions and Recommendations of the Committee of Independent Experts on Company Taxation (Luxembourg: Commission of the European Communities).Google Scholar
  68. Shome, P. and C. Schutte (1993) ‘Cash-Flow Tax’, IMF Staff Papers, vol. 40, pp. 638–62.CrossRefGoogle Scholar
  69. Sinn, H.-W. (1985) Capital Income Taxation and Resource Allocation (Amsterdam: North-Holland).Google Scholar
  70. Sinn, H.-W. (1991) ‘Taxation and the Cost of Capital: The “Old” View, the “New” View and Another View’, in D.F. Bradford (ed.), Tax Policy and the Economy, Vol. 5 (Cambridge, Mass.: MIT Press for the National Bureau of Economic Research).Google Scholar
  71. Skaar, A.A. (1991) ‘Norway Enacts Tax Reform of the Century’, Tax Notes International, November, pp. 1169–72.Google Scholar
  72. Smith, S. (1993) ‘“Subsidiarity” and the Co-ordination of Indirect Taxes in the European Community’, Oxford Review of Economic Policy, vol. 9, no. 1, pp. 67–94.CrossRefGoogle Scholar
  73. Sørensen, P.B. (1988) ‘Wealth Taxation, Income Taxation, and Saving’, University of Copenhagen, Institute of Economics, Blue Mimeo, no. 163.Google Scholar
  74. Sørensen, P.B. (1994a) ‘From the Global Income Tax to the Dual Income Tax: Recent Tax Reforms in the Nordic Countries’, International Tax and Public Finance, vol. 1, pp. 57–79.CrossRefGoogle Scholar
  75. Sørensen, P.B. (1994b) ‘Some Old and New Issues in the Theory of Corporate Income Taxation’, Finanzarchiv, vol. 51, pp. 425–56.Google Scholar
  76. Sørensen, P.B. (1995) ‘Changing Views of the Corporate Income Tax’, National Tax Journal, vol. 48, pp. 279–94.Google Scholar
  77. Sunley, E.M. (1992) ‘Corporate Integration: An Economic Perspective’, Tax Law Review, vol. 47, pp. 621–43.Google Scholar
  78. Swedish Ministry of Finance (1991) The Swedish Tax Reform of 1991 (Stockholm: Norstedts Tryckeri).Google Scholar
  79. Tanzi, V. and L. Bovenberg (1990) ‘Is There a Need for Harmonizing Capital Income Taxes within EC Countries?’, in H. Sieber (ed.), Reforming Capital Income Taxation (Tübingen: Mohr for the World Economic Institute, Kiel).Google Scholar
  80. Tikka, K.S. (1993) ‘Finland: Fundamental Tax Reform (25 percent Rate on Capital Income and Corporate Income)’, Bulletin for International Fiscal Documentation, June, pp. 348–53.Google Scholar
  81. US Department of the Treasury (1979) Blueprints for Basic Tax Reform (Washington, DC: US Government Printing Office).Google Scholar
  82. US Department of the Treasury (1984) Tax Reform for Fairness, Simplicity, and Economic Growth (Washington, DC: US Government Printing Office).Google Scholar
  83. US Department of the Treasury (1992) Integration of the Individual and Corporate Tax Systems: Taxing Business Income Once (Washington, DC: US Government Printing Office).Google Scholar
  84. Vogel, K. (1990) ‘World-wide vs. Source Taxation of Income: A Review and Reevaluation of Arguments’, in McLure, Musgrave et al., Influence of Tax Differentials on International Competitiveness (Deventer: Kluwer).Google Scholar
  85. Warren, A.C. (1981) ‘The Relation and Integration of Individual and Corporate Income Taxes’, Harvard Law Review, vol. 94, pp. 719–800.CrossRefGoogle Scholar
  86. Warren, A.C. (1991) Reporter’s Memorandum No. 3, ALI Federal Income Tax Project, Integration of the Individual and Corporate Income Taxes (Philadelphia, Penn.: American Law Institute).Google Scholar
  87. Warren, A.C. (1993) Reporter’s Study of Corporate Tax Integration, ALI Federal Income Tax Project, Integration of the Individual and Corporate Income Taxes (Philadelphia, Penn.: American Law Institute).Google Scholar
  88. Weiner, J. (1992) ‘Tax Coordination and Competition in the United States of America’, Annex 9C in Ruding Committee, Conclusions and Recommendations of the Committee of Independent Experts on Company Taxation (Luxembourg: Commission of the European Communities).Google Scholar
  89. Williams, J. (1988) ‘Efficient Signalling with Dividends, Investment, and Stock Repurchases’, Journal of Finance, vol. 43, pp. 737–47.CrossRefGoogle Scholar
  90. Zodrow, G.R. (1991) ‘On the “Traditional” and “New” Views of Dividend Taxation’, National Tax Journal, vol. 44, pp. 497–510.Google Scholar

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© Palgrave Macmillan, a division of Macmillan Publishers Limited 1998

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  • Sijbren Cnossen

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