Full Taxation: The Single Tax Emperor's New Clothes
Florida Tax Review, Vol. 24, Forthcoming
39 Pages Posted: 18 Jul 2020
Date Written: June 26, 2020
Ruth Mason has recently argued that the OECD Base Erosion and Profit Shifting project (BEPS) reflects and effectuates what she identifies as full taxation, a new international norm that suggests that all of a company’s income should be taxed in places where it has real business activities, representing the modern downside departure of single taxation. This article builds upon Mason’s work and argues that although rhetorically attractive, full taxation is still conceptually inconsistent, particularly because it is incapable to provide any hints as regards where and who should finally be taxed. Most notably, the concept also adopts an over-inclusive and instrumental approach, whose purpose appears to be no other than legitimizing what Mason denominates ‘fiscal fail-safe’ rules, that is, provisions under which if one country does not impose taxation, another country automatically pulls the trigger and does it, ultimately reinforcing the unpalatable idea of taxing just for the sake of taxing.
Keywords: full taxation; non-taxation; double taxation; double non taxation; single taxation
JEL Classification: K34
Suggested Citation: Suggested Citation