Exchange of tax information : neutrality and inter-nation equity

Thesis

Tax information exchange has been one of the principal themes in taxation related multilateral dialogue over the past ten years. This dialogue has been influenced by competing claims that various concepts of fairness, equity or efficiency supported particular proposals to reform tax information exchange practices. Much of the debate has focused on considerations of administrative efficiency and inter-individual equity in a single state context, to the exclusion of issues related to global welfare and inter-nation equity. The lack of consideration given to inter-nation equity highlights a gap in the tax literature.

The first part of this thesis locates the research and poses a series of questions relating to the theory underlying concepts of fairness, inter-nation equity and the neutrality of taxation systems in the context of tax information exchange. It illustrates that while theory suggests that the provision of tax information to foreign tax authorities may enhance tax administration efficiency and assist in ensuring horizontal and vertical equity among taxpayers in a single state, it also suggests that it may do so in some instances at the expense of global economic efficiency and inter-nation equity. New constraints on tax information exchange are proposed as mechanisms which will decrease the risk of undermining inter-nation equity and economic efficiency.

The second part of this thesis presents a case study examination of the extent to which considerations of inter-nation equity and fairness have influenced the evolution of proposals for tax information exchange in the context of the Organisation for Economic Cooperation and Development's Harmful Tax Competition Initiative. It also examines the extent to which international regime theory may contribute to an understanding of that Initiative and its proposals for tax information exchange.

The final part of the thesis presents a series of answers to the questions posed as well as observations relating to the implications for both theory and policy arising from the answers.

Authors: Rose, C

• Peer review status: Peer reviewed
• DOI: 10.5287/ora-1zx8k9qor
• Type of award: DPhil
• Level of award: Doctoral
• Awarding institution: University of Oxford