Calich, Isabel
(2011)
The impact of globalisation on the position of developing countries in the international tax system.
PhD thesis, London School of Economics and Political Science.
Abstract
The objective of this thesis is to analyse the relationship between international taxation
and developing countries. The main idea is to examine this relationship through
arguments that challenge the current legal debate that has described their interest as
capital importers of foreign direct investment.
Globalisation has changed the economic relations between developed and developing
countries. The evolution of the economic aspects as well as tax policies implemented
during the process of globalisation provides the background necessary to understand the
increased importance of international taxation and the participation of developing
countries in the global economy.
The hypothesis tested here addresses the question whether the dichotomy between
developing and developed countries and their characterisation as capital importers and
capital exporters still provides an appropriate basis for the legal debate on international
taxation in the context of globalisation. To approach this question, the behaviour of
international flow of capital will be assessed in order to provide an overview of the
economic relations among these countries.
To perform this study, initially the meaning of globalisation and international taxation
are explained in order to build up the framework of this thesis; secondly, the current
debate on harmful tax competition is examined to put in evidence the problem addressed
in this thesis; thirdly, an analysis of the international flow of capital is performed to
identify new premises that could update the legal debate; fourthly, based on the profile
of the international flow of capital, the phenomenon of capital flight is addressed.
Fifthly, having in mind the difficulty in taxing capital flight, taxation of portfolio
investment is examined. Based on the arguments raised, the legal debate is updated
demonstrating the higher importance of double taxation over tax avoidance and evasion
in the recent past. Finally, considering the increased relevance of international tax
avoidance and evasion, instruments available for exchange of information are analysed,
and their effectiveness to curb capital flight from developing countries.
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