La tassazione delle imprese nella competizione internazionale

The Author, after comparing German and Brasilian business tax law rules, generally analyses business taxation in the context of international tax competition. Tax competition is devised as part of the worldwide competition for global wealth among Nations. Following the four rules elaborated by Adam Smith in his well known essay on the Wealth of Nations (equality, certainty, convenience of payment, economy in collection), the Author reviews the most relevant issues concerning a suitable business taxation in the actual global scenario. He criticizes some of the most relevant models of optimal taxation of companies (such as cash-flow income tax, dual income taxation, interest adjusted business income tax) and, since there is no neutral business tax in force, he takes account of the dualism between income taxation and business taxation applied by many Nations. At the same time, he emphasises the outwardly unrelenting trend towards a consumption-oriented taxation. Finally, tax competition is considered as a great opportunity to both improve tax law and increase the efficiency of domestic fiscal policies. In fact, States cannot demand an “at will” tax burden anymore; they are forced to set up their fiscal systems in a way that should be attractive for the most productive activities. Fiscal authorities ought to be cooperative and promote a mutual exchange of information, especially in order to fight against harmful tax competition and tax fraud, such as the flight of capital to tax havens.