Sol picciotto, international business taxation 1992. The beps monitoring group a tjnbacked group led by sol picciotto. Business taxation 1992, and regulating global corporate capitalism 2011, several. Sol picciotto the international centre for tax and. Pdf indeterminacy, complexity, technocracy and the reform. To deal with this problem, double taxation treaties were concluded between countries, and as a result a paradigmatic shift in international tax law occurred. Reforming corporate taxation at the global level is the key step required to rebuild quality public services, tackle inequality and create the conditions necessary for economically sustainable growth. Sol picciotto is emeritus professor, lancaster university. Recent oecd proposals december 2018 panel discussion in the presence of pascal saintamans, oecd, led by sol picciotto, uk, and followed by panel discussion.
Indeterminacy, complexity, technocracy and the reform of international corporate taxation. Towards unitary taxation of transnational corporations sol picciotto summary this paper puts forward proposals for a reform of taxation of transnational corporations tncs. Coordination and leg itimacy in internati onal business taxation sol picciotto lancaster university law school abstract this paper wil l outline the changing forms of cooperation between national tax authorities in the taxation of income or profits from international business, especially transnational corporations tncs. The columbia journal of world business vol 28, issue 2. Unitary taxation of tncs and its relevance for extractive industries sol picciotto1 abstract heightened concern about the impact of international tax avoidance by transnational corporations tncs has led to new pressures for the radical revision of international corporate tax rules. International businesstaxation astudyintheinternationalization of business regulation solpicciotto emeritusprofessor,universityoflancaster. Although it would involve a new approach to this issue, it builds on long experience. Emeritus professor, lancaster university, senior adviser, tax justice network, and author of international business taxation 1992, and regulating global corporate capitalism 2011. Qureshi, the public international law of taxation graham and trotman, martinus nijhoff, 1994 pp. Oct 27, 2019 reforming corporate taxation at the global level is the key step required to rebuild quality public services, tackle inequality and create the conditions necessary for economically sustainable growth. Workshop on international law, natural resources and. Drawing upon experience with unitary approaches to corporate income taxation of the extractive sectors in subnational taxation systems of the united. Fragmented states and international rules of law sol picciotto lancaster university, u. Taxing multinational enterprises as unitary firms ids opendocs.
Taxation with special reference to developing countries. Sol picciotto attended the g20 antalya summit, and he had this to say. Sol picciotto, emeritus professor lancaster university united kingdom, coordinator of the beps monitoring group, and senior fellow international centre for tax and development. Coordination and legitimacy in international business taxation. Is the international tax system fit for purpose, especially. Google scholar picciotto, sol 1992a international business taxation. International taxation and intrafirm pricing in transnational corporate groups author links open overlay panelsolpicciotto.
The g20 and the base erosion and profit shifting beps project. This paper traces the history of international corporate taxation, discusses how. Fixing the global corporate tax rules is an essential part of an inter. A study in the internationalization of business regulation, 1992 at pp 56. Toward unitary taxation of transnational corporations. A read is counted each time someone views a publication summary such as the title, abstract, and list of authors, clicks on a figure, or views or downloads the fulltext. Fragmented states and international rules of law sol. Sol picciotto born 1942 is a syrianborn british academic, emeritus professor of law at lancaster university. This paper sets out a new approach to international corporate taxation and argues for new set of international standards that are fairer, easier to understand, more certain and predictable for. Towards unitary taxation of transnational corporations sol picciotto1 1 emeritus professor, lancaster university, senior adviser, tax justice network, and author of international business taxation 1992, and regulating global corporate capitalism 2011. Regarding these double taxation treaties certain conventions commonly known as model conventions on double taxation more will be said about this in a little. This paper analyses whether a global unitary taxation approach to corporate income tax cit can improve the ability of governments to design and administer efficient and effective tax and royalty policies for the extractive industries.
Picciotto, sol 1983 jurisdictional conflicts, international law and the international state system, international journal of the sociology of law, vol. Financing development in africa nov 30dec 6 2014 nairobi, kenya. Sol picciotto has taught at the universities of dar es salaam 196468, warwick 19681992 and lancaster 19922007, where he is now emeritus professor. Sol picciotto specializes in international business regulation and economic law, and in the social theory of law, and is joint editor of social and legal studies. I am grateful for comments from michael durst, ted van hees, david spencer and. Unitary taxation in the extractive industry sector. Although states tend to be increasingly formally committed to tackling avoidance, they do so in a system that promotes contradictory sets of behaviour. The case study will illustrate broader trends of transformation both of statehood and the international state system, from the classical liberal model based on interdependence and coordination. International tax, regulatory arbitrage and the growth of transnational corporations sol picciotto this paper traces the history of international corporate taxation, discusses how transnational corporations tncs, through their tax advisers, have helped to shape the system, and suggests that this is important in understanding the development. Sol picciotto international business taxation sage journals. International taxation and intrafirm pricing in transnational corporate. Introduction the theme of this and the other articles of this issue, linkages as a phenomenon in international economic law, involves some technical legal questions of considerable interest, as well as some. Rights, responsibilities and regulation of international.
This paper will outline the changing forms of cooperation between national tax authorities in the taxation of income or profits from international business, especially transnational corporations tncs. Contemporary populism is rooted in a crisis of legitimacy. International business taxation tax justice network. So i decided to sit down in the british national archives. It is all about how states choose their route in the new international tax. International businesstaxation astudyintheinternationalization ofbusinessregulation solpicciotto emeritusprofessor,universityoflancaster. May 14, 2014 picciotto, sol, is the international tax system fit for purpose, especially for developing countries. It is a significant achievement for the g20 and oecd tax experts to have been able to deliver a consensus package of proposals for international tax reforms. However, this should be regarded as not the end but the beginning of a longer process. Sol picciotto was born in aleppo, syria in 1942, of jewish parents.
Indeterminacy, complexity, technocracy and the reform of. Read the new report, towards unitary taxation of transnational corporations by sol picciotto, emeritus professor at lancaster university, senior adviser with tax justice network and author of international business taxation 1992, and regulating global corporate capitalism 2011, here. A study in the internationalization a study in the internationalization of business regulation, electronic republication london, 1992, 2. Towards unitary taxation financial transparency coalition. Abstract globalisation, as the latest phase in the development of the world system, involves a fragmentation and restructuring of state forms, in which law is being called upon to. International centre for tax and development working paper. International tax, regulatory arbitrage and the growth of. Its global profits are then allocated out to the countries where it does business. Iv global tax policy conference maastricht university. The various initiatives to strengthen international tax coordination are examined, focusing especially on the problems of i legitimising cooperation based on governmental and professional networks, and ii coordination between taxation and related regulatory issues, especially supervision of financial institutions and markets e. The g20 and the base erosion and profit shifting beps. Pascal st amans director, centre for tax policy and administration oecd.
Regulating global corporate capitalism sol picciotto download. This system would mean instead of related companies being treated and taxed as separate entities, they would be taxed as a single unit on their consolidated accounts. All content included on our site, such as text, images, digital downloads and other, is the property of its content suppliers and protected by us and international. Public services international psi is a global trade union federation representing. It quickly provoked an international storm and was notably denounced by the chair of the taxation commission of the international chamber of commerce, wolfgang ritter, as nothing but another form of unitary taxation cited in picciotto, 1992. Pdf indeterminacy, complexity, technocracy and the. This tends to undermine attempts to solve the problem of avoidance unless a more transformative collective. While i knew that the united nations initially tried and failed to pick up the leagues work, the interregnum between 1946 and 1963 is often raced over quite quickly in tax history stories. A study in the internationalization of business regulation by sol picciotto in epub, fb2, fb3 download ebook. International businesstaxation tax justice network. International business taxation astudyintheinternationalization of business regulation solpicciotto emeritusprofessor,universityoflancaster. A unitary taxation system is needed to remove the incentives for tncs to shift their tax burden towards more favourable tax regimes picciotto, 2007. Regulating global corporate capitalism sol picciotto. Read the new report, towards unitary taxation of transnational corporations by sol picciotto, emeritus professor at lancaster university, senior adviser with tax justice network and author of international business taxation 1992, and regulating global corporate capitalism 2011.
Picciotto, sol, is the international tax system fit for purpose, especially for developing countries. The select committee on economic affairs inquiry on taxing corporations in a global economy. Regulating global corporate capitalism by sol picciotto. He is the author of international business taxation 1992, and regulating global corporate capitalism 2011, several coedited books, and numerous articles and book chapters, on international economic and business law and regulation. Solutions the international tax system is rigged in favour of multinational enterprises, at the expense of smaller companies and other taxpayers. A study in the internationalization of a study in the internationalization of business regulation london, 1992, 2. He is the author of international business taxation 1992 and regulating global corporate capitalism 2011, several coauthored books, and numerous articles on international economic and. He has taught at the university of dar es salaam and the university of warwick, and is now professor of law at the university of lancaster. A study in the internationalization of business regulation new edition by picciotto, sol isbn.
Corporate tax avoidance by multinationals is one cause of that crisis. Erika dayle siu, sol picciotto, jack mintz and akilagpa sawyerr. He has taught at the university of dar es salaam and the university of warwick. Coordination and legitimacy in international business. His family left syria in 1947 to 1948, and he was educated at manchester grammar school. At the same time countries are, rightly so, concerned about. Rights, responsibilities and regulation of international business. Written by sol picciotto and daniel bertossa for public. G20 oecd beps project public consultation on transfer pricing matters paris 1112 october 2016. Tjna academy sol picciotto free download as powerpoint presentation. Sol picciotto ba oxford, jd chicago is an emeritus professor at lancaster university, a senior adviser of the tax justice network, coordinator of the beps monitoring group and chair of the advisory group of the international centre for tax and development, where he coordinates and carries out research on the taxation of transnational corporations with special reference to developing countries. Sol picciotto is emeritus professor at lancaster university uk, and. The g20 and the base erosion and profit shifting beps project sol picciotto with agustina gallardo jeffery kadet markus henn.
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