In view of the public financial needs caused by the Ukraine war or Corona pandemic on the one hand and its very different economic effects on sectors and companies on the other, a so-called Excess Profits Tax is being discussed in various countries. This would allow the "winners" of the crisis, who record high sales and profits in the years of the pandemic, to be called upon to finance the public costs of the Ukraine war or as example the Corona pandemic more heavily. The excess profits tax is described as a "tax on the excess amount over the profit of a previous base period, e.g. the excess profits tax. The excess profits tax is described as "a tax on the excess of a profit over the profit of a previous base period, e.g. the excess profits tax during the First and Second World Wars in the UK and the US". An excess profits tax is levied on the profit in excess of a "normal profit" or a "normal rate of return"; what is to be considered a "normal" profit and what is to be considered an "excess" profit can be calculated in different ways. Against this background, the question is asked about the objective and functioning of the excess profits tax during the two world wars in the USA as well as in France, about the state of the international debate with regard of both the first and second Pillar and possibly on the introduction of an excess profits tax as a third Pillar, about different forms of calculating excess profits as well as about the possibility of introducing an excess profits tax in Germany, taking into account in particular the constitutional and tax aspects. The Italian legal order is examined with regard of its windfall profit taxation especially according to the Decree Law ) adopted by the Italian Government on 18 March 2022, promulgated on 21 March 2022 and entered into force on 22 March 2022 and compared with the EU Guideline on windfall profit taxation.

Filippo Luigi Giambrone, Considerations regarding the Windfall Profit taxation regarding the International and European taxation framework. The German and Italian framework concerning windfall profit taxation.

Filippo Luigi Giambrone
2023-01-01

Abstract

In view of the public financial needs caused by the Ukraine war or Corona pandemic on the one hand and its very different economic effects on sectors and companies on the other, a so-called Excess Profits Tax is being discussed in various countries. This would allow the "winners" of the crisis, who record high sales and profits in the years of the pandemic, to be called upon to finance the public costs of the Ukraine war or as example the Corona pandemic more heavily. The excess profits tax is described as a "tax on the excess amount over the profit of a previous base period, e.g. the excess profits tax. The excess profits tax is described as "a tax on the excess of a profit over the profit of a previous base period, e.g. the excess profits tax during the First and Second World Wars in the UK and the US". An excess profits tax is levied on the profit in excess of a "normal profit" or a "normal rate of return"; what is to be considered a "normal" profit and what is to be considered an "excess" profit can be calculated in different ways. Against this background, the question is asked about the objective and functioning of the excess profits tax during the two world wars in the USA as well as in France, about the state of the international debate with regard of both the first and second Pillar and possibly on the introduction of an excess profits tax as a third Pillar, about different forms of calculating excess profits as well as about the possibility of introducing an excess profits tax in Germany, taking into account in particular the constitutional and tax aspects. The Italian legal order is examined with regard of its windfall profit taxation especially according to the Decree Law ) adopted by the Italian Government on 18 March 2022, promulgated on 21 March 2022 and entered into force on 22 March 2022 and compared with the EU Guideline on windfall profit taxation.
2023
eu taxation law- international taxation law- windfall profit taxation
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Utilizza questo identificativo per citare o creare un link a questo documento: https://hdl.handle.net/20.500.12070/60499
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