Corporate/shareholder income taxation and allocating taxing rights between countries; a comparison of imputation systems

This book from the IBFD proposes a fundamental change to the norms for the allocation of taxing rights among countries. The author uses an in-depth study of imputation systems to expose the flaws in the current international order, arguing that it is theoretically unsound. He then develops an alternative that would resolve many of the problems presented by international tax law today. Imputation systems are founded on a philosophy that corporations are not appropriate subjects of income taxation, other than as vehicles for the collection of tax, and they accordingly seek to alleviate economic double taxation. In practice they do not achieve this aim. In a domestic context, considered in the first four chapters, their inconsistencies and inaccuracies obscure the more fundamental flaws of the income taxation systems of which they form a part. In an international context, considered in the second four chapters, the difficulties associated with imputation systems highlight the deficiencies in current norms for the allocation of taxing rights among countries. The author examines those norms and finds them an inadequate basis for the international order. The alternatives he proposes would place the international taxing order on a firm theoretical footing and could be applied to any type of corporate tax system. If adopted, his proposals would obviate the need for much current international tax law. Treaties, measures for the avoidance of double taxation and many anti-avoidance measures would become superfluous.