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Erscheinungsjahr: 
2024
Schriftenreihe/Nr.: 
Research Paper No. 211
Verlag: 
South Centre, Geneva
Zusammenfassung: 
Taxation of cross-border services has been identified as a high priority issue in the United Nations (UN) negotiations to establish a new global framework for tax. This paper analyses the defects of international tax rules as applied to services, and their exploitation by multinational enterprises (MNEs), focusing on the impact on developing countries. Services have become increasingly important for economic development, but international tax rules favouring delivery by non-residents act as a disincentive to the growth of local services providers, particularly disadvantaging developing countries which are mainly hosts to MNEs. We analyse the restrictions on source taxation of services in tax treaties, particularly those based on the model of the Organisation of Economic Co-operation and Development (OECD), and show that their spread has been accompanied by a widening deficit in services trade of developing countries, while the weakening of their attempts to protect their tax base through withholding taxes has resulted in increasing losses of tax revenue. The paper combines detailed qualitative analyses of tax treaties with quantitative estimates of their effects on trade and tax revenues for services of five developing countries: Argentina, Brazil, Colombia, Kenya and Nigeria. Our analysis suggests that a new approach is needed for taxation of services, breaking with the residence-source dichotomy, and adopting formulary apportionment. This could be based on the standards agreed in the Two Pillar Solution of the OECD/Group of Twenty (G20) project on base erosion and profit shifting (BEPS) and developed now through the UN.
Schlagwörter: 
Argentina
Base Erosion and Profit Shifting Project (BEPS)
Brazil
Colombia
Global Tax
Global Taxation
International Tax
International Tax Cooperation
International Tax Reform
International Taxation
Kenya
Multinational Enterprises (MNEs)
Nigeria
Organisation for Economic Co-operation and Development (OECD)
Services
Tax
Tax Cooperation
Tax Law
Tax Policy
Tax Reform
Taxation
Taxing Rights
Two Pillar Solution
United Nations (UN)
Dokumentart: 
Research Report
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