Verotuksen ja talouden territoriaalisesta kytköksestä verotusvallan ekstraterritoriaalisuuteen. Poliittisten ideoiden murros ylikansallisessa yritysveroreformissa
Avainsanat:
vero-oikeus, talouden globalisaatio, yritysverotus, eurooppaoikeus, verokilpailu, veronvälttelyAbstrakti
Towards extraterritoriality in corporate taxation: International corporate tax reform and the transformation of policy ideas
For a long time, the international corporate tax system relied on the idea of taxing firms where they perform economic activities. Gradually, the system became undermined by the deep economic globalisation, which tore apart the territorial nexus between taxation and economy. The 2010s international tax reform set out to devise legal rules capable of re-implementing the idea of taxing where economic value is created. Yet, in a more recent phase, the reform has partly renounced the idea. This has become evident in the context of the EU minimum corporate tax rules. This article puts forward that, in its more recent phase, the reform is compelling people to rethink political ideas shaping the allocation of taxing rights among countries. Thus far, it has failed to do so. The article points to a legitimacy gap that must be overcome by rearticulating the key premises of corporate taxation.
