Consultation on an IMF 2019 Analysis of International Corporate Taxation

October 2018

The IMF thanks the organizations and individuals who provided comments for the online consultation on an IMF 2019 Analysis of International Corporate Taxation. The online consultation ended on December 10, 2018. If you have any questions, please send an e-mail to

The IMF Fiscal Affairs and Legal Departments are preparing a paper on the international corporate taxation system and the possible future directions it will or could take. This is scheduled to be presented to the IMF Executive Board in February 2019.

The upcoming study will build on the 2014 IMF Policy Paper on Spillovers in International Corporate Taxation, which (i) provided a broad characterization of the current international tax architecture; (ii) identified and quantified the spillovers induced by the then-current system; (iii) elaborated on the specific challenges for developing countries; (iv) discussed some alternative systems.

The new IMF study will (A) assess the current state of the international tax system, including developments over the last five years; (B) elaborate in more depth on alternative futures; and (C) reflect on current and possible arrangements for the governance of international taxation.

The paper does not aim to set international standards for taxation (which is not within the remit of the IMF), but rather the objective is to stimulate and inform the thinking of policy makers and others at a time of significant developments in the long-standing architecture of international taxation.

Questions for consultation

The IMF is seeking your views as valuable inputs in drafting this new analysis. While we welcome comments on any aspect of the international corporate taxation system, we are specifically interested in receiving feedback on some or all of the following questions:

  1. How do you view the current state of the international corporate taxation system?

    For example:
    • What do you see as the main successes or shortcomings of the OECD Base Erosion and Profit Shifting (BEPS) project?
    • How does it affect developing countries?
    • What are your views on recent tax reforms in the US and elsewhere?
    • Are problems with the current principles of international taxation (residence and source bases; arm’s length pricing…) becoming harder to deal with?
    • In your view, is the allocation of taxing rights and profit attribution to countries problematic?

  2. Assuming that the world continues with broadly the current international tax architecture, what does the future of corporate tax look like?

    For example:
    • How will digitalization and the growing importance of intangibles and “user participation” (e.g., through search engines or social media) affect the system in terms of fairness, efficiency and implementation?
    • How effectively can future tax policy changes be implemented into the existing international architecture?
    • Will tax competition intensify or moderate?

  3. Can unitary/formulary methods help address weaknesses of the current architecture? If a full shift to formulary apportionment is not possible, what is your view of using some form of residual profit split in cases where arm’s length pricing doesn’t work well or make sense?

  4. Several proposals include elements of destination-based taxation (i.e. allocating tax base, perhaps in part, to the place of the final sale)? What pros and cons do you see in this, both in principle and in practice? Do you see the current system as already moving towards destination-based principles (e.g. interim digital taxation measures)?

  5. Should tax bases be changed to target only “economic rents”— “excess profits”—leaving the taxation of “normal” returns to the shareholder level (or not taxing them at all)?

    For example, this could entail using a cash-flow tax or Allowance for Corporate Equity or Capital system that allows immediate deduction at the corporate level of all investment costs, or allows an annual deduction for a standard return to invested equity as if it were debt.

  6. What do you think of proposals (or reforms such as the recently enacted US “GILTI” provision) to impose some form of minimum corporate income tax?

  7. What is your view of taxes targeted specifically at digital activities of various forms?

  8. How do you assess current arrangements for international tax cooperation or coordination? Are they adequate to address weaknesses you may see in the current international tax architecture?

  9. Please feel free to raise any other issues that you think the IMF paper should address.

How to participate

Interested stakeholders are encouraged to email their responses to the questions above and any other comments to by Monday, December 10, 2018, COB Eastern Standard Time.

Please include the following information when responding via email so that the comments can be registered. Senders may request for their responses and comments to be private.

  • Name of the sender
  • Organization you represent (if any)
  • Country (headquarters)
  • Phone number
  • E-mail address

A summary of the responses will be posted on our website and included in the final board paper.