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Title: Exchange of Tax Information: Neutrality and Inter-Nation Equity
Author: Rose, Christopher
Awarding Body: University of Oxford
Current Institution: University of Oxford
Date of Award: 2007
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Tax infonnation 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 refonn tax information exchange practices. Much ofthe debate has focused on considerations of administrative efficiency and inter-individual equity in a single state context, to the exclusion ofissues 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 ofthis thesis locates the research and poses a series of questions relating to the theory underlying concepts offaimess, inter-nation equity and the neutrality of taxation systems in the context oftax information exchange. It illustrates that while theory suggests that the provision of tax infonnation 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 ofthis thesis presents a case study examination ofthe extent to which considerations of inter-nation equity and fairness have influenced the evolution of proposals for tax information exchange in the context ofthe 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 fmal 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.
Supervisor: Not available Sponsor: Not available
Qualification Name: University of Oxford, 2007 Qualification Level: Doctoral
EThOS ID:  DOI: Not available