In the last four years,there has been increasingconcern by developed countries about the potential erosion of the corporate income tax base by "harmful tax competition"。However,the date on tax compatition available to date present a mixed and somewhate puzzling pictures。On the one hand,there is conciderable evidence that effective coporate income tax rates in many countryies have been declining,and that the worldwide effective tax rates on multinational enterprise(MNEs)have been going down as well。On the other hand,macroeconomic data from developed countries do not indicate a significant decline in corporate income tax revenues。Part of the explanation for this phenomenon is that despite the advent of e-commerce,MNEs find it harder than some commentators have predicted to avoid having a permanent establishment(PE)in market jurisdictions。As a result,MNEs ara still taxed--and may be taxed more heavily --in countries where they sell their goods,assuming a PE exist。These countries ara largely developed countries,so it is not surprising that their revenue date show no decline in corporate tax revenue。The decline in effictive coporate tax rates may therefore be attributable more to tax competition in jurisdictions where MNEs produce their goods,which ara more likely to be developing countries,which ara compateting to attract real foreign investment。The data therefor shows that decling effective tax rates is primarily due to tax competition for manufacturing activity,and the lack of residual residence-based taxation。If this conjecture is correct ,tax competition may be harming developing countries more than developed economies。 |