Full Taxation: The Single Tax Emperor's New Clothes

Florida Tax Review, Vol. 24, Forthcoming

39 Pages Posted: 18 Jul 2020

See all articles by Leopoldo Parada

Leopoldo Parada

University of Leeds School of Law

Date Written: June 26, 2020

Abstract

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

Parada, Leopoldo, Full Taxation: The Single Tax Emperor's New Clothes (June 26, 2020). Florida Tax Review, Vol. 24, Forthcoming, Available at SSRN: https://ssrn.com/abstract=3636073 or http://dx.doi.org/10.2139/ssrn.3636073

Leopoldo Parada (Contact Author)

University of Leeds School of Law ( email )

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HOME PAGE: http://https://essl.leeds.ac.uk/law

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