This paper presents the results of a survey of senior tax professionals in large businesses and in professional firms on the uncertainty of corporation tax in major countries. The survey was undertaken between January and March 2016. 88 respondents answered questions about 25 countries. The respondents were from businesses in 10 different countries. Over 10% of the world’s businesses with turnover in excess of $5 billion were respondents. The main results were as follows:
• Of 21 countries analysed, BRIC countries take up 4 of the top 5 places in respondents’ assessments of the extent of corporation tax uncertainty.
• In the last 5 years, corporation tax uncertainty has increased in 20 out of 21 countries analysed.
• Overall, respondents ranked corporation tax uncertainty third in a list of factors influencing business investment and location decisions. 72% ranked this as either 4 or 5 on a scale of 1 to 5 with 5 indicating “extremely important”. This was more important than the anticipated tax rate itself.
• In the experience of respondents, BRIC countries take up the top 4 places in frequency with which corporation tax uncertainty has had a serious impact on business decisions.
• The single most important factor in determining uncertainty is “unpredictable or inconsistent treatment by tax authority”. However, the importance of different factors varies across countries, and this factor is more important in BRIC countries than in the UK and the USA. Another factor, very important in both groups of countries, is “complexity in the tax code”.
This work formed the basis of a subsequent study and survey undertaken by the OECD.
Michael P. Devereux, CBT Working Paper 16/13