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A Destination-Based Corporate Tax

Explore the need for reform in international tax rules, addressing issues of inter-nation equity, BEPs, and jurisdiction. Delve into proposals for substantive jurisdiction and compliance obligations to enhance fairness and effectiveness. Join Professor Rita De La Feria in discussing the unsuitability of current rules and identifying key areas for improvement.

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A Destination-Based Corporate Tax

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  1. School of Law A Destination-Based Corporate Tax RITA DE LA FERIA Professor of Tax Law, University of Leeds 2 June 2017 EATLP Congress 2017, Lodz

  2. OUTLINE • Current International Tax Rules • Why current rules are no longer suitable • BEPs and other anti-avoidance rules • Proposals for Reform • Substantive Jurisdiction • Legitimacy • Inter-nation equity • Enforcement Jurisdiction • Identifying destination • Compliance obligations • Legal obligations • Conclusions

  3. UNSUITABILITY OF CURRENT RULES • Always questions over its inter-nation equity, and effects on developing countries • But a “flawed miracle”, where jurisdiction to tax was clear • Created for 1920s economy, started to falter with globalisation • Mobility of factors of production meant jurisdiction to tax no longer clear

  4. UNSUITABILITY OF CURRENT RULES

  5. UNSUITABILITY OF CURRENT RULES

  6. UNSUITABILITY OF CURRENT RULES COUNTRIES THAT CONTRIBUTE TO PRODUCTION OF A SINGLE JAR OF NUTELLA

  7. BEPS AND OTHER ANTI-AVOIDANCE RULES

  8. BEPS AND OTHER ANTI-AVOIDANCE RULES

  9. PROPOSALS FOR REFORM

  10. PROPOSALS FOR REFORM Criteria for Reform of CIT

  11. PROPOSALS FOR REFORM Is Destination the Location Which Creates Least Distortion To Economic Behaviour?

  12. SUBSTANTIVE JURISDICTION TO TAX

  13. SUBSTANTIVE AND ENFORCEMENT JURISDICTION TO TAX

  14. SUBSTANTIVE JURISDICTION TO TAX

  15. SUBSTANTIVE JURISDICTION TO TAX

  16. ENFORCEMENT JURISDICTION TO TAX

  17. CONCLUSIONS

  18. School of Law 7th in the UK for Law The Times and Sunday Times Good University Guide 2017 THANK YOU University of the Year 2017 The Times and The Sunday Times Good University Guide

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