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The study presents place names and site names (toponyms) found in the Maltese islands and which comprise Greek words or have origins in the Greek language. With a focus on maritime connections, it presents historic events which would have brought harbour communities in close encounter with the Greek language and culture. Through a multidisciplinary approach the study analyses placenames and site names still used or found in historical documents, backed by archaeological evidence, oral tradition, cartography, other knowledge, and studies. Findings show that in the Maltese islands, placenames mirroring or containing Greek words occur at sea inlets and creeks which could have served as harbours; however, the occurrence of both place names and site names is higher in the south of Malta and around its ancient harbour, witnessing to higher contacts between the two cultures. The study concludes that connections between the Maltese islands and the Greek cultures happened mostly in maritime harbours owing to events in history which gave importance to the use of the Greek language or Greek maritime terminology. Keywords: Greek, harbour, Malta, maritime, Mediterranean, toponyms

The study introduces twelve Mediterranean insular grassroots micromuseums and their collections. Curators were asked a set of questions concerning their collections, thus, the message intended, the method applied, and sources of information used to interpret the collection. They were also asked about the involvement of others and negotiation in interpretation, presentation, and decision-making concerning selection and display of objects. Based on replies, the study showed that while the collections displayed promote a theme, they primarily intend to build connections and bring together communities, whether by place, shared interest, practice, or past experiences such as history or specific events in history. Besides the intended connections, collections displayed at grassroots micromuseums could raise further and deeper connections with different communities and visitors. Also, depending on the curators’ choices, collections displaying different identities at such museums could create more personal connections than impersonal collections aimed to promote a homogenous identity.

The objective of this research was to inquire whether it is possible to trace and document remote unwritten history from toponyms and oral lore among other indications which survive among ancient m...

This book undertakes a fundamental review of the existing international regime for taxing business profit. It steps back from the current political debates on how to combat profit shifting and how taxing rights over the profits of the digitalized economy should be allocated. Instead, it starts from first principles to ask how we should evaluate a tax on business profit—and whether there is any good rationale for such a tax in the first place. It then goes on to evaluate the existing regime and a number of alternatives that have been proposed. It argues that the existing regime is fundamentally flawed, and that there is a need for radical reform. The key conclusion from the analysis is that there would be significant gains from a reform that moved the regime towards taxing profit in the country in which a business made its sales to third parties. That conclusion informs two proposals that are put forward in detail and evaluated: the Residual Profit Allocation by Income (RPAI) and the Destination-based Cash Flow Tax (DBCFT). The book is authored by group of economists and lawyers—the Oxford International Tax Group, chaired by Michael Devereux. It draws insights from both economics and law—including economic theory, empirical evidence on the impact of taxes, and a detailed examination of practical issues of implementation—to assess the existing system and to consider fundamental reforms. This book will be useful to tax policy makers, tax professionals, academics, and anyone interested in tax policy.

The United Kingdom (UK) adopted “value creation” as the guiding principle for designing its digital services tax (DST). This article argues that this principle acts as a double-edged sword. On the ...

This chapter sets out the key conceptual issues that arise in designing a business-level tax on profit in an international setting. It is in four parts—each addressing a basic question. First, what is meant by a tax on profit? We identify different approaches to taxing profit and show that there are a number of equivalences between taxes. Second, what criteria should be used for evaluating a business-level tax on profit in an international setting? We set out five criteria in some detail: economic efficiency, fairness, robustness to avoidance, ease of administration, and incentive compatibility. Third, given these criteria, is a business-level tax on profit a useful addition to the set of taxes that can be employed by national governments? We consider different possible underlying rationales for taxing business profit, especially in an international context. Fourth, is taxation at both the business and the owner-level problematic? We consider whether there is need for relief from this form of double taxation.

This chapter sets out and evaluates a number of possible reform options; we group options by four broad locations in which profit could be taxed. First, profit could in principle be taxed in the country of residence of the owners of the business. A second option is the country of residence of the parent company or business headquarters. A third option is the country where the business undertakes its functions and activities, or where its assets—defined broadly to include financial assets—are held. We refer to this location as ‘origin’. And finally, a business could be taxed in the location of its customers. We refer to this location as ‘destination’. Each of the activities taking place in these four locations might be thought to be necessary, but not sufficient, for the generation of profit, and therefore generate a nexus which would justify taxation. We evaluate specific options according to the five criteria set out in Chapter 2.

In this chapter we explain the broad approach taken in the two detailed proposals set out in Chapters 6 and 7, namely the RPAI and DBCFT respectively. We discuss the extent to which international coordination would be required, or desired. We then consider the costs of transition to a new system. In broad terms, we can compare incremental reforms which are based on the existing structure, with more fundamental reforms that more radically change that fundamental structure. We also discuss what should be required in terms of revenue requirements, and the likely redistribution of revenues among countries. We then discuss two issues which are common to the two options: the scope of the tax and the concept and definition of destination.

The key problems confronting the international tax system are introduced in this chapter—including problems of tax avoidance through shifting profit to low tax countries, distortions to international investment and trade created by the existing system, and two different forms of competition between countries. The main ideas of the book are introduced, including the approach of the book which addresses the issue of designing an international tax system on business profit from first principles. It explains the key direction of reform—moving to allocating tax rights to the country in which businesses sell their goods and services.

This chapter sets out and evaluates our second main proposal: the Destination-based Cash Flow Tax (DBCFT). This has two basic components: (a) a ‘cash flow’ element, which gives immediate relief to all expenditure, and (b) a ‘destination-based’ element, which introduces border adjustments of the same form as under the value added tax (VAT): exports are untaxed, while imports are taxed. This is equivalent in its economic impact to introducing a broad-based, uniform rate VAT and making a corresponding reduction in taxes on wages and salaries. A central motivation for the DBCFT is to improve economic efficiency by taxing business income in a relatively immobile location; the DBCFT should not distort either the scale or the location of business investment. It also has the considerable advantage of being robust against avoidance through inter-company transactions.

This chapter sets out our first detailed reform proposal: the Residual Profit Allocation by Income (RPAI). This is one of a family of schemes based on separating multinational profit into ‘routine’ and ‘residual’ profit, a distinction that exists under the current system. The RPAI allocates the right to tax routine profit to the country where functions and activities take place. It allocates the right to tax residual profit to the market, or destination, country where sales are made to third parties. We evaluate the RPAI against our five criteria. We conclude that while it is far from perfect, it performs well against these criteria. Its superior performance stems primarily from allocating taxing rights for residual profit to the destination country, where there is a relatively immobile third party purchaser of goods and services sold by the company.

This article provides some preliminary thoughts on tax policy and the COVID-19 crisis. In the first part, it discusses fiscal measures available to policymakers in response to the COVID-19 crisis. The role of taxation will evolve over the different phases of the pandemic: measures have already been adopted to respond to the crisis in the short-term, but questions remain as to the types of measures that should be adopted in the medium and longer-term. In the second part, this article discusses the current and possible future effects of the pandemic on international tax policy. COVID-19, tax policy, international tax reform, transfer pricing, profit shifting, tax and the digital economy.

Digitalization exacerbates the problems faced by the existing system for taxing corporate profit in an international context. It does so by making it much easier for all aspects of a company to be spread around the world: its shareholders and creditors, its operations and its consumers. As many of these problems ultimately stem from the fact that the existing system taxes companies in the location of their mobile factors, this article argues that a more direct and satisfactory response to these problems would be to move to a system in which companies are taxed where their immobile factors are located. The article considers two such possibilities: the location of shareholders and that of consumers. It also considers two specific issues which arise particularly in the context of digital companies, namely two sided markets and free usage.

This paper considers the implications of the destination-based cash flow tax (DBCFT) for three common ways of shifting taxable profits between countries: through manipulation of transfer prices, the use of debt, and locating intangible assets in low taxed jurisdictions. It shows that none of these planning devices would be available under a DBCFT, if adopted universally. This is because intra-group payments between two countries do not affect tax liabilities in either country . If adopted unilaterally, however, there would be an incentive to shift profit to the adopting country, at the expense of non-adopting countries.

This article provides some preliminary thoughts on tax policy and the COVID-19 crisis. In the first part, it discusses fiscal measures available to policymakers in response to the COVID-19 crisis. The role of taxation will evolve over the different phases of the pandemic: measures have already been adopted to respond to the crisis in the short-term, but questions remain as to the types of measures that should be adopted in the medium and longer-term. In the second part, this article discusses the current and possible future effects of the pandemic on international tax policy.

In the wake of the 2007-2008 financial crisis, a large number of countries have introduced levies on bank borrowing with the aim of reducing risk in the financial sector. This paper studies the behavioral responses to the bank levies and finds that banks exposed to levies increased their reliance on equity financing, but at the same time increased the risk of their assets. This represents the first empirical evidence of banks shifting risk from the liability side of their balance sheets to the asset side to mitigate the impact of government intervention. Our analysis also shows that while levies were successful in reducing the overall risk of the average bank, the effect was concentrated among banks that pose no or little threat to financial stability.

This paper is a draft chapter of a forthcoming book on the taxation of international business profit by the authors of this paper, to be published by Oxford University Press. The group has been meeting regularly for five years, to identify and discuss the key problems of the existing international tax system, and to develop potential options for reform. The book will study two proposals for reform in depth. One is the destination-based cash flow tax – a draft chapter on this proposal has already been released. The second proposal – for a form of residual profit allocation - is presented here. This paper is largely self-standing and can be read without necessarily reading the rest of the book, although it does refer in places to arguments set out in other draft chapters.

Innovation and its main output, technology, are changing the way we work, socialise, vote, and live. New technologies have improved our lives and made firms more productive, overall raising living standards across the world. Thanks to progress in information technology, the rate of change is accelerating. Disruption and disequilibrium are the new normal. In this essay, prepared as a chapter for the first phase of the British Academy ‘The Future of the Corporation’ initiative, we reflect upon the role that corporate, competition and tax law can play both to facilitate innovation and simultaneously assuage emergent societal risks arising from new technologies. We consider means of enhancing investment in research and development (‘R&D;’) and optimising corporate organisation. But we also reflect on the risks associated with innovation, such as the use of technology to exploit consumers, manipulate markets or distort, unwittingly or not, the political process. Finally, we consider the way in which the environment for business law reform is subject to new political risks following the challenge to the liberal order from populism and the rising power of dominant technology companies.

It is now widely taken as axiomatic that the existing international corporate tax system is based on the principle that corporate profits are taxed where value is created (the “value creation principle”). There also appears to be widespread agreement, at least amongst policymakers, that the system should be based on this principle. This policy paper disputes both these descriptive and normative claims.

The most significant problems with the existing system for taxing the profit of multinational companies stem from two related sources. First, the underlying ‘1920s compromise’ for allocating the rights to tax profit between countries is both inappropriate and increasingly hard to implement in a modern economic setting. Second, because the system is based on taxing mobile activities, it invites countries to compete with each other to attract economic activity and to favour ‘domestic’ companies. The OECD Base Erosion and Profit Shifting (BEPS) initiative essentially seeks to close loopholes rather than to re-examine these fundamental problems. As a consequence, it is unlikely to generate a stable long-run tax system. We briefly outline some more fundamental alternative reforms.

This paper presents, analyses, and further develops the idea of a destination-based cash-flow tax (DBCFT). Its purpose is expositional: to describe the DBCFT, how it might work, what its effects would be and some of the challenges that its implementation would face. The paper starts by introducing the basic mechanics of the DBCFT before evaluating it against five criteria: economic efficiency, robustness to avoidance and evasion, ease of administration, fairness and stability. It does so both for the case of universal adoption by all countries and the more plausible case of unilateral adoption. The paper then looks closely at the application of DBCFT treatment to the financial sector, which is a familiar problem under the VAT but has been little considered under the DBCFT. Finally, the paper sets out some core implementation issues, and how they might be addressed. It also compares the implementation of a DBCFT with the economically equivalent reform option that introduces a broad-based, uniform rate VAT (or achieves the same effect through an existing VAT), and reduces taxes on payroll by the same proportion.

To operate efficiently and effectively revenue authorities require discretion, but processes must be in place to keep discretion in check. This delicate balancing act takes place against the background of a more general constitutional framework. This working paper starts by outlining the unique features of the UK constitution that form the background to the way in which the discretion of the UK revenue authorities (HMRC) is assessed and controlled. It then discusses a limited, yet crucial, set of discretions vested in HMRC. The paper focuses particularly on the use of non-statutory guidance. It discusses the operation of judicial review, and in particular, the doctrine of legitimate expectations, in the context of such guidance. It then presents two case studies, which reveal a distinct uncertainty over the limits of non- statutory guidance. This is currently of considerable concern to the UK tax community. As the role of guidance appears to be increasing in the UK system, the case for addressing some of these causes of uncertainty strengthens. The paper concludes by offering some preliminary suggestions on how the problems may be addressed.

Transactions designed to avoid statutory provisions bear the legal risk that courts deem them unsuccessful. As this legal risk is a function of the approach courts adopt towards them, identifying and understanding it fully is a sine qua non requirement, without which one simply cannot assess the risk ex ante. Confidence in the robustness of such transactions is based partly on the fact that UK courts characterise transactions according to their legal substance, ignoring factors such as economic substance. Courts have developed an approach in the tax field, the so-called “Ramsay Approach”, which can lead them to look beyond legal substance, but the view seems to be held in some quarters that it cannot be applied outside the tax field. It is argued here that, once its true nature is properly understood, this approach not only can but actually has been applied in a number of corporate law cases.

In the wake of the fi?nancial crisis, a number of countries have introduced levies on bank borrowing with the aim of reducing risk in the ?financial sector. This paper studies the behavioural responses to the bank levies and evaluates the policy. We find that the levies induced banks to borrow less but also to hold more risky assets. The reduction in funding risk clearly dominates for banks with high capital ratios but is exactly offset by the increase in portfolio risk for banks with low capital ratios. This suggests that while the levies have reduced the total risk of relatively safe banks, they have done nothing to curb the risk of relatively risky banks, which presumably pose the greatest threat to fi?nancial stability.

Against the backdrop of the debate over the introduction of a fi nancial transaction tax (FTT) in the European Union, this Forum is dedicated to the discussion of issues concerning the implementation and impact of such a tax on the fi nancial sectors of the member states. Dorothea Schäfer regards as the main policy goal of an FTT to be the prospect of slowing down the mutually reinforcing and growing trends of an increasing number of derivative products and shorter holding periods. The FTT can therefore make an important contribution to preventing the decoupling of financial markets from the real economy. The paper by Stephan Schulmeister discusses the essential features of a general FTT that will ensure that the more short-term oriented and riskier a transaction is, the greater the effect of the FTT on transaction costs. John Vella identifies some commonly made claims about an FTT which are of questionable foundation and compares the FTT with some alternative taxes on the financial sector. Donato Masciandaro and Francesco Passarelli focus on how an FTT measure aimed at reducing fi nancial systemic risk can cause political distortions, leading to inefficient and ineffective policies. Finally, the paper by Ross Buckley analyses common myths, inaccuracies and untruths about the EU's proposed FTT.

To operate efficiently and effectively revenue authorities require discretion, but processes must be in place to keep discretion in check. This delicate balancing act takes place against the background of a more general constitutional framework. This chapter outlines the unique features of the UK constitution that form the background to the way in which the discretion of the UK revenue authorities (HMRC) is assessed and controlled. It then discusses a limited, yet crucial, set of discretions vested in HMRC. The chapter focuses particularly on the use of non-statutory guidance. It discusses the operation of judicial review, and in particular, the doctrine of legitimate expectations, in the context of such guidance.

There have been various calls for the introduction of a Financial Transaction Tax (otherwise known as a Robin Hood Tax or a Tobin Tax) in recent times. The EU Commission published a proposal for an EU-wide Financial Transaction Tax on the 28th of September 2011. John Vella, Clemens Fuest and Tim Schmidt-Eisenlohr have written a paper responding to the EU Commission’s proposal.

This paper analyzes the results of a survey of views of large businesses regarding recent UK Government initiatives aimed at modifying taxpayer behaviour and tackling what is perceived by the tax authorities acting on behalf of Government to be unacceptable/aggressive tax avoidance. Specifically, it examines the views of tax directors obtained from face-to-face interviews conducted in spring 2008 with representatives of 30 corporate groups regarding alternative approaches to tax risk and tax avoidance. The paper first describes the experiences and opinions of large business representatives with respect to the Risk Rating Approach, a key feature of the HMRC links with large business programme (Varney Programme), as well as the status of relationships between HMRC and large business more generally. It next considers the respondents’ views on the practical implications of two developing legislative approaches – targeted anti-avoidance rules (TAARs) and principles-based legislation (PBL) – and how these approaches impact upon and are influenced by relationships between HMRC and large businesses.

The natural history of organ transplantation across the MHC barrier in the absence of immunosuppression is that of rejection. There are clearly defined periods at which a graft is at risk [1]. Registry data indicate that the period of greatest risk for acute rejection is within the first 3–6 months post-transplantation. Beyond the first post-transplant year, the risk of acute rejection diminishes substantially, although the risk never diminishes to zero (Figure 1). The introduction of newer and more potent immunosuppressive therapies combined with effective anti-microbial prophylaxis has resulted in a significant decline in the incidence of acute rejection and graft loss over the last 25 years [1],[2]. Currently available immunosuppressive agents effectively prevent rejection in most, although not all, transplant recipients. It is apparent that there is a degree of interpatient variability in the requirements for immunotherapy. For example, the risk of acute rejection is greater in children, African-Americans and in recipients who are sensitized to HLA [3]. Taken together, these observations have provided the rationale for the development of induction immunosuppressive strategies that minimize the risk of rejection for a given individual. However, there is no consensus on what constitutes the optimal prophylactic induction immunosuppressive therapy to prevent renal allograft rejection.