No description available.

Subject of the thesis is comparison of Tax Systems of The Czech Republic and Germany. The objective of the thesis is to analyze the tax systems of Germany and the Czech Republic, it's parts and final comparison. The thesis is focused on tax reforms, income tax and other direct taxes, social security and health insurance. Additionally, it is focused on indirect taxes, value added tax and various consumption taxes. There is a comparison of impact of different income taxes at various income levels of the tax payer in the end.

Abstract There are currently three arguments in the treatment of business tax in Taiwan's integrated income tax system. They are the income tax expense argument, appropriation of net income of income tax argument, and income tax asset argument. Among them, the income tax expense argument is mainly adopted. The purposes of this study are, first, to examine the legitimacy of the regulations of the current financial accounting principles as well as the arguments of scholars and experts. Then we try to find a more perfect accounting treatment model. Finally, we study the current income tax law regulations to check if it is absolutely necessary to set up an imputation credit account outside the book of account. This study finds that the current system is not legitimate enough to fulfill the requirements of an idealized accounting treatment model. The nature of business tax in our integrated income tax system should depend on the attributive situation rather than judging its nature and accounting treatment by the above mentioned three arguments. Therefore, this study proposes an innovative argument entitled Income Tax Attribution Argument. The logic of this new system is primarily to analyze the attributes for income tax according to current tax law; then judge its nature by its attributive situation; finally, decide its accounting treatment in accordance with its nature. According to our current income tax law, there are at least seven categories of attributive situations. The differences among their natures are so large that we have to distinguish them. The mistake that the income tax expense argument makes is that it attempts to treat various accounting affairs by a single accounting concept and method. Part of the differences among their natures were mentioned in the appropriation of net income of income tax argument and income tax asset argument, but no further study appeared later. Therefore, this study tries to bring out a new method of business income tax based on the attributive situation. We examine the nature and accounting treatment method according to four aspects: business entity convention, ownership theory, classification definition, and matching principle. The result shows that it has more advantages, even though it is a bit complex, and hence is a more perfect accounting treatment model compared to the others. The Income Tax Attribution Argument proposed by this study lists the classification of applying deductible tax amount formally to record the unapplied deductible tax amount. This classification can replace the shareholders' account of unapplied deductible tax amount. Therefore, it is unnecessary to set up an imputation credit account outside the book of account as is done in the current income tax law regulations.

This paper empirically tests a theory laid out in Scholes et al. (2015, p. 315) that the U.S. worldwide tax system reduces the incentive of U.S. parent companies to be tax aggressive in their foreign subsidiaries. Investors subject to a worldwide tax system pay taxes on their worldwide income, regardless of the origin thereof. Therefore, a U.S. investor pays the difference between the effective tax payment abroad and the higher U.S. statutory tax when profits are repatriated. In contrast, investors subject to territorial tax systems gain the full tax savings from being tax aggressive abroad. Our results show that U.S.-owned foreign subsidiaries have a by 1.2 percentage point higher average GAAP effective tax rate (ETR) compared to subsidiaries owned by foreign investors from countries with a territorial system. We contribute to the literature by showing a mechanism, other than cross-country profit shifting, why U.S. multinational companies have higher GAAP ETRs than multinationals subject to territorial tax systems. (authors' abstract) / Series: WU International Taxation Research Paper Series

The growth in multinational corporations looking to expand and invest in foreign countries, particularly in the emerging markets such as Africa, has grown tremendously. “Africa is already the world’s second fastest growing economy after expanding 5% a year in the past two years, well above the global average.” (World Economic Forum, 2013). This has resulted in the movement of human capital between different tax jurisdictions and an increase in expatriates all across the world. The focus of the study is to expand on the current knowledge on the taxation of inbound expatriates working within South Africa, Botswana, Namibia and Nigeria, as the world has turned its focus on Africa in terms of investment and expansion, as supported by Shelley (2004:3), and to provide both employers and employees with knowledge of the different tax regimes (source-based taxation and residence-based taxation) found in some of the emerging and fastest growing markets in Africa: namely Botswana, Namibia, Nigeria and South Africa. It was found that the African tax landscape provides for a vast range of tax systems, of which, most are either residence–based or source-based. The tax systems of South Africa and Nigeria are similar in that they are residence-based. In each of these two countries, tax residents are taxed on their worldwide income, while non-residents are only taxed on income from specific sources. Therefore, residency is an essential concept in each of these tax systems. The above-mentioned countries, however, apply different methods and factors in determining the concept of residency. As a result of the difference in determining tax residency and differences in their domestic income tax legislations, the taxability of income earned abroad differs in these countries. The tax systems of Botswana and Namibia are similar in that they are source-based. In each of these countries, income is taxable when it is from a source or deemed source within these countries. Although in exceptional circumstances, some income which is not from a source within these countries may be taxable, relief is applied in terms of the domestic legislation, in order to lessen the burden of tax. Source is therefore a vital concept in each of these tax systems. The definition and application of the term source is different in both countries. However, similarities are found in that the source is primarily where the services were physically rendered. Both employers and employees should consider the basis of taxation (source basis and residence basis) that is applied by the prospective host country when making a decision regarding an assignment to a foreign country as this forms a major factor in how their income (both local and foreign) will be treated. / Dissertation (MCom)--University of Pretoria, 2013. / Taxation / unrestricted

O ambiente ecológico do Planeta sofre incontáveis alterações, primordialmente, pela ação humana diante da transformação, consumo e descarte dos bens naturais. Tais atitudes resultam em significativa relevância na degradação ambiental e requerem imposição estatal a fim de controlar e/ou impedir maior devastação. Dentre as formas pelas quais o Estado pode combater o processo de poluição, encontram-se os chamados instrumentos econômicos. É exemplo deste mecanismo estatal o tributo ecológico, que desperta interesse em face de seu forte poder de indução comportamental. Embora, nesse aspecto, a utilização da tributação não seja ferramenta inédita, pode-se afirmar que foi com a substituição do Estado Liberal para o Estado Intervencionista que o uso da tributação com escopo de ajuste comportamental se enfatizou. Como o ordenamento jurídico brasileiro ainda não apresenta um verdadeiro tributo ecológico, da forma prevista e defendida pela OCDE Organização para Cooperação e Desenvolvimento Econômico, o tema mostra-se atual e relevante, notadamente, pela experiência internacional que tem demonstrado a capacidade de alcançar resultados significativos no combate à poluição do meio ambiente natural por meio do tributo ecológico. Assim, a proposta do trabalho consiste em abordar a compatibilidade de um tributo ecológico com o sistema tributário nacional. Nesta seara, são abordados os temas relativos aos contornos da extrafiscalidade e da indução tributária, as formas de intervenção do Estado na economia e os seus limites, o desenvolvimento econômico, a proteção ambiental e as externalidades e, ainda, a relação entre a ordem tributária, a ordem econômica e a defesa do meio ambiente, presentes no texto constitucional, em especial, no que se refere aos princípios da legalidade, da igualdade, da livre concorrência e da defesa do meio ambiente. Igualmente, é objeto da pesquisa a análise da legislação estrangeira, por meio do direito comparado para investigação da mais adequada espécie tributária para fins de proteção ambiental. Em sede de conclusão, analisa-se acerca da compatibilidade ou não de um tributo ambiental com o sistema tributário nacional. Para melhor desenvolver o estudo, este último tópico é dividido em duas vertentes: uma teórica acerca do sistema tributário nacional - e uma análise pragmática acerca da sua exequibilidade. Assim, experimentam-se as espécies tributárias existentes no vigente sistema tributário a fim de verificar o veículo mais adequado a ser utilizado como um possível tributo ecológico. / Earths ecological environment undergoes countless changes, mainly brought about by human action on the processing, use and disposal of natural resources. Such attitudes result into a significant outstanding of the environmental degradation, requiring state ruling in order to control and/or prevent greater devastation. The so called economical instruments are among the ways through which the government is able to fight the polluting process. The ecological tax, which arouses interest on account of its strong environmental induction power, is one of the examples of such instruments. Although, under this aspect, the utilization of taxation is not an unheard of tool, one may assert it was through the substitution of the liberal government by the interventionist one that the use of environmental adjustment-scoped taxation, got to be emphasized. Since the Brazilian legal arrangement has yet to put forth an actual ecological tax, as it was foreseen and defended by OCDE Economical Development and Cooperation Organization, the matter shows to be current and relevant, notably, by the international experience which has demonstrated its ability on reaching significant results in the fight against the natural environments pollution by means of the ecological tax. Thus, the present study aims to address compatibility of an ecological tax with the National taxing system. In this scope it examines all issues pertaining the outlines of tax induction and extra fiscal measures forms of state intervention in the economy and its boundaries, economical development, environmental protection and their externalities. And yet, the relation among tax policy , economic policy and environmental protection as presented in the constitution, especially on what refers to legal, equity, free competition and environmental protection principles. Likewise, this research aims to analyze the foreign legislation, by means of comparing the right for investigating the most suitable tax for environmental protection purposes. In conclusion we analyze the compatibility, or not, of an environmental tax with the national tax system. So as to better develop this study, this latter issue is divided into two parts, a theoretical one about the national tax system a pragmatic one and about their feasibility. Thus, experience whether existing taxes on the current tax system in order to ascertain the most suitable one for being used as a possible ecological tax.

Este trabalho analisa as razões do recorrente fracasso das reformas tributárias no Brasil. Foram estudadas três tentativas de reforma - uma no governo FHC e duas no governo Lula. Apesar de o sistema tributário brasileiro ser muito mal avaliado, todas estas tentativas de reforma falharam. A hipótese central do trabalho é que este fracasso não pode ser explicado pelas estruturas políticas ou federativas, mas pela estratégia dos governos. A ampla insatisfação com os tributos no Brasil induz o governo a propor reformas abrangentes, que alteram muitos aspectos da intrincada estrutura tributária. Estas propostas acabam gerando conflitos multidimensionais, ou seja, o aparecimento de muitas clivagens políticas simultâneas. Também se compara a reforma tributária a outras duas grandes reformas do período: a reforma do judiciário e a reforma administrativa. / This thesis analyzes the reasons for the persistent failure of the tax reforms in Brazil. I studied three attempts at reform one in Cardosos and two in Lulas administration. Although the Brazilian tax system is rated very poor, all these attempts have failed. The central hypothesis of this study is that failure can not be explained by political or federal sistem, but by the strategy of governments. Widespread dissatisfaction with taxes in Brazil induces the government to propose sweeping reforms that alter many aspects of the intricate tax structure. These proposals generated multidimensional conflicts: the emergence of many political cleavages simultaneously. I also compare the tax reform with two other reforms of the period: the reform of judiciary and administrative reform.

Comme le souligne Michàl Kalecki, la parution de la Théorie Générale a mis en exergue l’impact de la fiscalité sur la croissance économique. La théorie générale, notamment dans le chapitre XXXVI, a mis en lumière les effets bénéfiques que la fiscalité peut avoir sur la société mais sans en développer véritablement les aspects macroéconomiques importants. C’est Kalecki (1937 ; 1944) qui a véritablement mis en avant les propriétés macroéconomiques de la fiscalité à court terme, en étudiant comment les modifications de la structure fiscale influence la redistribution et la dynamique macroéconomique. Pour autant, la question de l’incidence fiscale a été surtout traitée par le courant standard où la fiscalité est observée du point de vue de ses effets désincitatifs sur les facteurs d’offre. Ce constat n’a rien d’exceptionnel si l’on tient compte de la posture académique prise par l’économie depuis la remise en cause de l’efficacité des politiques keynésienne et du développement des idées autour des questions d’incitation au début des années 1980, notamment celles qui touchent aux comportements d’activité des individus. Il faut remonter aux années 1920 pour trouver une description analytique d’une théorie de l’incidence fiscale. À cette époque Pigou se voit poser la question suivante par un jeune mathématicien nommé Ramsey : Quelle structure de la fiscalité des biens pourrait minimiser la perte de bien être à recettes données ? / No English summary available.

Salt is one of the most important materials to human beings. To the state, the salt tax is one of the most steady incomes in finance. The state may control the salt industry because of the necessary to his people , or finance. This research, starting from the relative autonomy of the state, tries to discuss the purpose of the state to control the salt industry, and at the same time, the state will take different salt systems for different purposes. Specifically, the state has its own purposes, and to reach them, the state will decide it`s salt system. This research will take three salt systems- the state monopolized system,taxation system,and non-tax system, and take three factors- political business relationship,production and marketing ways,the development of salt industry to realize the the state`s purposes and how the salt system works. This research discovered that the financial factor was usually the first purpose of the state. In the state monopolized system, durivg the Japanse period, the independence of Taiwan`s finance is the purpose of the state after 1915. In taxation system, the state took salt industry as public enterprise. In order to root in Taiwan, the state authorises the resource in Taiwan through public enterprise. The salt tax is one of the most steady incomes in the state finance. In the state monopolized system, the state did not control the production of salt products, but bought all kinds of salt products in forces. The state was not a producer, but a distributor. Therefore , the political business relationship was given and taken. This relationship did not change in taxation system, because the state was both producer and distributor, till non-tax system begun. In non-tax system, the political business relationship turns to competitive relation, for the state can not control the salt industry anymore, and the relative autonomy of the the state disappeared. The salt industry had a considerable progress during the periods of the state monopolized system and taxation system, because the salt industry had to coordinate the state policy to produce difference salt products. In non-tax system period , because of the opening of the salt products market , the salt industry turns to technical denseness industry. Finally, the salt industry was controlled by the state for finance purpose and coordinated the state`s policy.

none