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Picciotto2004 - Tax Jurisdiction Global Apportionment Law...

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1 Presentation to 2 nd Essex Conference 1st-2nd July 2004 Tax Competition and Tax Avoidance: Implications for Global Development Tax Jurisdiction & Global Apportionment Sol Picciotto Law School 2 Taxes & Jurisdiction Direct Taxes: employment income investment income: passive/portfolio active/direct Indirect Taxes: sales (VAT) transactional: stamp duty, air tickets, insurance Capital: Property gains death duties Payroll & Social Security Source or Residence deduction withholding Destination or Origin Place of transaction Physical location Residence Domicile/Residence Place of employment
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3 Jurisdiction to Tax Investment Income Home State Residence/nationality where recipient located Capital-export equity Host State Source: where income earned Capital-import equity investor business Home state Residence Host state Source investor Withholding Deduction at source 4 National Taxation of Transnational Firms “In a business of this nature you cannot say how much is made in this country and how much in another. You kill an animal and the product of that animal is sold in 50 different countries. You cannot say how much is made in England and how much is made abroad. That is why I suggest that you should pay a turnover tax on what is brought into this country. … It is not my object to escape payment of tax. My object is to get equality of taxation with the foreigner and nothing else.” (Sir William Vestey, to Royal Commission on Tax, 1915)
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