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LEZIONE 1
Struttura ed evoluzione dei
sistemi tributari
Tassazione internazionale delle società - PARTE I
Clamep
8 crediti – 50 ore
27.9.2010-6.11.2010
Principali fonti
 OECD, Revenue Statistics 1965-2008, 2009 Edition
http://www.oecd.org/document/4/0,3343,en_2649_34533_41407428
_1_1_1_1,00.html
“This annual publication presents a unique set of detailed and
internationally comparable tax revenue data in a common format for
all OECD member countries from 1965 onwards. It also describes a
conceptual framework to define which government receipts should be
regarded as taxes and to classify different types of taxes.
The 2009 edition includes a Special Feature titled ‘Changes to the
guidelines for attributing revenues to levels of government’.
2
 Eurostat and European Commission, Taxation trends
in the European Union, 2010 edition
http://ec.europa.eu/taxation_customs/resources/documents/taxatio
n/gen_info/economic_analysis/tax_structures/2010/2010_full_text
_en.pdf
“This is the fourth issue of 'Taxation Trends in the European Union', an
expanded and improved version of a previous publication, 'Structures of
the taxation systems in the European Union'. The objective of the report
remains unchanged: to present a complete view of the structure, level
and trends of taxation in the Union over a medium- to long-term period.
Taxation is at the heart of citizens' relationship with the State. Not only
government experts and academics, but also citizens regularly address
us questions about taxation levels in the EU and on how Member States
compare with each other; this report, which is published annually, is
one way of answering these questions….
….. This publication presents time series of tax revenue data from
National Accounts for the twenty-seven Member States Norway, and for the first time - Iceland. It provides a breakdown of taxes according to
different classifications: by type of taxes (direct taxes, indirect taxes,
social contributions), by level of government, and by economic function
(consumption, labour, capital). It also compiles data for the sub-group of
environmental taxes.”
3
OECD Revenue statistics
 Total tax revenue as percentage of GDP (p. 19)
These ratios are calculated by expressing total tax revenues as a
percentage of GDP at current market prices. Tax ratios vary
considerably between countries, as does their evolution over time.
In 2007, two countries in the European region – Denmark and
Sweden – had tax ratios of 45 per cent or more of GDP. In contrast,
seven countries – Japan, Korea, Mexico, the Slovak Republic,
Switzerland, Turkey and the United States – had tax ratios of below
30 per cent. In 2007, the tax ratio in the OECD area as a whole
(unweighted average) remained stable at 35.8 per cent (see Table A),
0.2 percentage point below the highest recorded level in 2000.
Overall tax ratios rose in fourteen OECD member countries whereas
they fell in fifteen countries. In three countries, the increases in tax
ratios were one percentage point of GDP or more, the highest being
in Hungary (2.4 points). The reductions in the ratio were generally by
less than one percentage point.
4
OECD Revenue statistics
 Total tax revenue as percentage of GDP
Taking a long term view and focusing on major OECD areas, in
Canada, Mexico and the United States the tax-take from GDP inched
up from an (unweighted) average of 25.2 per cent in 1965 to 26.5 per
cent in 2007. In OECD Europe, by contrast, between 1965 and 2007
the overall tax/GDP ratio increased from 26.2 per cent to 38.0 per
cent. In OECD Pacific, the corresponding figures were from 21.1 per
cent to 30.4 per cent.
The trend towards higher tax levels over this period reflects the
sizeable increase of public sector outlays in almost all industrialised
countries, with recourse of governments to alternative ways to
finance their spending – non-tax revenues, borrowing and printing
money – being limited for a variety of reasons.
5
Total tax ratio as percentage of GDP, 2007 (page 40)
6
Changes in tax to GDP ratio (in percentage points) (page 44)
1995-2007
7
OECD Revenue statistics
 Tax structure
Tax structures are measured by the share of major taxes in total tax
revenue. While, on average, tax levels have been rising, the share of
main taxes in total revenues – the tax structure or tax “mix” – has
been remarkably stable. Nevertheless, several trends have emerged,
as shown in Table C.
In 2007, personal income taxes had ceased to be the largest single
source of revenue for OECD countries as a whole. Their share had
shrunk to 25 per cent of total taxes from 30 per cent in the early
1980s (unweighted averages). The variation in the share of the
personal income tax between countries is considerable. In 2007, it
ranged from a low of 9 per cent in the Slovak Republic and 12 per
cent in the Czech Republic to 42 per cent in New Zealand and 52 per
cent in Denmark
8
OECD Revenue statistics
 Tax structure
Over the last decade, the share of the corporate income tax in the
tax mix has increased by about 3 percentage points of total taxes
(unweighted average), to exceed the 9 per cent level of the 1960s. As
with the personal income tax, the share of the corporate income tax
in total tax revenues shows a considerable spread (see Table 13 in
Section II.A), from 6 per cent (Austria) to 23 per cent (Australia) and
26 per cent (Norway). Apart from the spread in statutory rates of the
corporate income tax, these differences are at least partly explained
by institutional factors or the exploitation of mineral deposits – the
degree to which firms in a country are incorporated, taxation of oil
revenues – and the erosion of the corporate income tax base, for
example as a consequence of generous depreciation schemes and
other instruments to postpone the taxation of earned profits.
Taken together, taxes on personal and corporate incomes remain
the most important source of revenues used to finance public
spending in half of all OECD countries, and in eight of them –
Australia, Canada, Denmark, Iceland, New Zealand, Norway,
Switzerland and the United States – the share of income taxes in the
tax mix exceeds 45 per cent
9
OECD Revenue statistics
 Tax structure
The declining share of the personal income tax for OECD countries
taken together was paralleled by the growing share of social
security contributions, which by 2007 accounted for 25 per cent of
total tax revenues. In seven countries – Austria, the Czech Republic,
France, Germany, Greece, the Netherlands and the Slovak Republic
– social security contributions are now the largest single source of
general government revenue (see Table 7 in Section II.A). The
expanding share of contributions in the tax mix (up from 18 per cent
of total revenues in 1965) seems to be directly linked to the upward
pressure on aggregate benefit spending resulting from ageing
populations and rising government expenditure on health care
programmes. In 2007, the share of social security contributions in
the tax mix varied from 2 per cent (Denmark) to 40 per cent (the
Slovak Republic) and 44 per cent (Czech Republic). Australia and
New Zealand report no revenue from social security contributions
(see Table 15 in Section II.A). OECD countries also show a wide
variety in the relative proportions paid by employees and employers
(see Tables 17 and 19 in Section II.A).
10
OECD Revenue statistics
 Tax structure
Between 1965 and 2007, the share of taxes on immovable
property, net wealth plus property and legal transactions
fell significantly, from 8 per cent to 6 per cent of
aggregate tax revenues, possibly in part as a result of
voter resistance against such highly “visible” taxes and a
failure to maintain up-to-date the inflation-adjusted
valuation of the tax base.
11
OECD Revenue statistics
 Tax structure
The share of taxes on consumption (general consumption
taxes plus specific consumption taxes) fell from 36 to 30 per
cent between 1965 and 2007. But in addition the mix of taxes
on goods and services has fundamentally changed. A fast
growing revenue source has been general consumption
taxes, especially the value-added tax (VAT) which is now
found in twenty-nine of the thirty OECD countries. General
consumption taxes presently produce 19 per cent of total tax
revenue, compared with only 14 per cent in the mid-1960s. In
fact, the substantially increased importance of the valueadded tax has everywhere served to counteract the
diminishing share of specific consumption taxes, such as
excises and custom duties. Between 1965 and 2007 the share
of specific taxes on
consumption (mostly on tobacco, alcoholic drinks and fuels,
including some newly introduced environment-related taxes)
was halved. Rates of taxes on imported goods were
considerably reduced everywhere, reflecting a global trend 12
to
remove trade barriers.
Taxation trends in the EU (2010 ed.)
Nel 2008 si inizia a sentire l’effetto della crisi
“The effects of the global economic and financial crisis have hit the
EU with increasing force from the second half of 2008, which is the
last year for which we possess tax revenues data with the high level
of disaggregation needed for the purposes of this report. This means
that our revenue data refer only to the beginning of the recession,
and not to its entire development. Developments in 2008 were also
marked by the circumstance that many countries still recorded
satisfactory growth in the first six months of 2008, so that the year as
a whole is made up of two rather uneven halves. Nevertheless, as we
shall see, the recession had a clear impact on revenues already in
2008, not only on capital taxes (typically highly sensitive to the pace
of growth), but also on consumption taxes, which are usually
expected to be somewhat more resilient in a slowdown; in particular,
consumption tax revenue shrunk more than the volume of
consumption itself. The overall revenue impact was a decline by 0.4
percentage points of GDP, compared with the year before, for capital
taxes, while revenue from consumption taxes contracted by 0.3
points of GDP.
13
 In media, la UE è un area a tassazione elevata
“The European Union is, taken as a whole, a high tax area. In 2008, the
overall tax ratio, i.e. the sum of taxes and social security contributions in
the 27 Member States (EU-27) amounted to 39.3 % in the GDP-weighted
average, more than one third above the levels recorded in the United States
and Japan. The tax level in the EU is high not only compared to those two
countries but also compared to other economies in general; among the
major non-European OECD members, only New Zealand has a tax ratio that
exceeds 34.5 % of GDP(2). As for less developed countries, they are
typically characterised by relatively low tax ratios.
The high EU overall tax ratio is not new, dating back essentially to the last
third of the 20th century. In those years, the role of the public sector
became more extensive, leading to a strong upward trend in the tax ratio in
the 1970s, and to a lesser extent also in the 1980s and early 1990s. In the
late 1990s, first the Maastricht Treaty and then the Stability and Growth
Pact encouraged EU Member States to adopt a series of fiscal
consolidation packages. In some Member States, the consolidation
process relied primarily on restricting or scaling back primary public
expenditures, in others the focus was rather on increasing taxes (in some
cases temporarily)….
14
 Ma c’è una grande variabilità fra paesi
Despite the high average level of the overall tax ratio, eleven Member
States display ratios below the 35 % mark, highlighting that differences
in taxation levels across the Union are quite marked; the overall tax
ratio ranges over more than twenty points of GDP, from 28.0 % in
Romania to 48.2 % in Denmark. In other words, the tax burden in the
highest-taxing EU Member State is over 70 % higher than in the least
taxing one.
These large differences of course depend mainly on social policy
choices like public or private provision of services such as old age
pensions, health insurance and education, on the extent of public
employment, or of State activities, etc..
Technical factors also play a role: some Member States provide social
or economic assistance via tax reductions rather than direct
government spending….
It should also be highlighted that the GDP value, that constitutes the
denominator of the overall tax ratio, includes estimates of production
by the informal sector (the 'grey' and 'black' economy); so that not only
low taxes, but also high tax evasion can result in a low overall tax ratio.
15
 Con una lieve tendenza alla convergenza
As a general rule, tax-to-GDP ratios tend to be significantly higher in
the old EU-15 Member States (i.e. the 15 Member States that joined
the Union before 2004) than in the 12 new Members; the first seven
positions in terms of overall tax ratio are indeed occupied by old
Member States. …..
… Despite these large differences, over the last years, until 2007 the
overall tax ratio tended to converge. The ratio between the standard
deviation and the mean of the overall tax ratios declined from 2001
to 2007; also the gap between the highest and the lowest overall tax
ratio showed a similar trend. In 2008, however, tax ratios diverged
again slightly, possibly owing to the rather different extent of the
slowdown within Member States….
16
 La struttura del prelievo: differenza fra
“nuovi” e “vecchi” stati membri
Generally, the new Member States have a different structure
compared with the old Member States; in particular, while most old
Member States raise roughly equal shares of revenues from direct
taxes, indirect taxes, and social security contributions, the new
Member States, with the notable exception of Malta, typically display
a lower share of direct taxes in the total. The lowest shares of direct
taxes are recorded in Bulgaria (only 21.0 % of the total, still
markedly up from 16.9 % in 2005, Slovakia (only 22.1 % of the total),
and the Czech Republic (23.8 %). One of the reasons for the low
direct tax revenues can be found in the generally more moderate tax
rates applied in the new Member States on the corporate income tax
and on the personal income tax. Several of these countries have
adopted flat rate systems, which typically induce a stronger
reduction in direct than indirect tax rates.
17
 La struttura del prelievo: vi sono differenza
anche fra i “vecchi” stati membri
Also among the old Member States (the EU-15) there are some
noticeable differences. The Nordic countries as well as the United
Kingdom and Ireland have relatively high shares of direct taxes in
total tax revenues. In Denmark and, to a lesser extent, also in Ireland
and the United Kingdom the shares of social security contributions
to total tax revenues are low.
There is a specific reason for the extremely low share of social
security contributions in Denmark: most welfare spending is
financed out of general taxation. This requires high direct tax levels
and indeed the share of direct taxation to total tax revenues in
Denmark is by far the highest in the Union. Among the old Member
States, the German and French tax systems represent in this
respect the opposite of Denmark's with high shares of social
security contributions in the total tax revenues, and relatively low
shares of direct tax revenues.
18
Altre tendenze: PIT
 From 1995 to 2009, almost all EU Member States cut their top rate.
Currently, the top personal income tax (PIT) rate amounts to 37.5
%, on average, in the EU. This rate varies very substantially within
the Union, ranging from a minimum of 10 % in Bulgaria to a
maximum of 56.4 in Sweden, as Denmark, which levied the
highest PIT maximum rate until last year, has cut it to 51.5 %.
 For the first time in several years, the top PIT rate has increased,
on average, in 2010, despite the sizeable Danish cut, as several
EU Member States enacted increases (the UK introduced a new 50
% rate, ten points higher than the previous maximum, but Greece
and Latvia too hiked their top rates).
 Lower PIT top rates do not necessarily imply a trend towards
lower PIT revenues, because in systems with several tax
brackets, the percentage of taxpayers taxed under the highest
rate is typically quite limited. In addition, changes in the tax
threshold can have important effects on the tax liability, even at
unchanged rates;
19
20
Altre tendenze: CIT (1)
 Similarly to the trend recorded for the PIT, since the
second half of the 1990s, corporate income tax (CIT) rates
in Europe have been cut forcefully, from a 35.3 % average
in 1995 to 23.2 % now. Unlike the case of the PIT, this trend
has not been interrupted by the financial crisis, on the
contrary a few Member States introduced further cuts in
2010 (the Czech Republic, Greece, Lithuania, Hungary,
Slovenia) and none increased them. (vedi grafico p.71)
 Although the downward trend has been quite general,
corporate tax rates still vary substantially within the Union.
The adjusted statutory tax rate on corporate income varies
between a minimum of 10 % (in Bulgaria and Cyprus) to a
maximum of 35.0 % in Malta, although the gap between the
minimum and the maximum has shrunk since 1995.
21
22
Altre tendenze: CIT (2)
 Some countries have implemented changes that go beyond
simple rate cuts. Estonia is a good example of this
development. The country moved away from the classical
corporation tax system: despite the low CIT rate (26 %) in
force since 1994, since the beginning of 2000 Estonia
decided to levy no corporate tax on retained profits, so that
only distributed profits are taxed. The rate was later cut to
21 %. A similar system had been introduced also in
Lithuania, but was later abolished. Another example is
Belgium, where the introduction of the notional interest
system has had the effect of reducing the tax burden fairly
significantly, even though it does not translate into a
change in the nominal tax rate.
23
Imposte societarie (CIT), personali
(PIT) e sul consumo
 Analysing the role of corporate taxation in the overall tax
systems of the OECD countries we find three main
interdependencies. First, countries with larger
governments tend to rely less on corporate taxation.
Further, it can be observed that corporate taxation and
personal income taxation tend to move together. On the
other hand, governments seem to compensate for
corporate tax reductions by increasing value-added taxes.
In consequence, over the last two decades, a shift from
income taxation towards consumption taxation, i.e. valueadded taxes, can be observed. So far this trend is most
pronounced for smaller European countries. However,
more recent tax reforms, most notably in Germany, indicate
that these tendencies might continue unabated and also in
larger economies. (Loretz, 2008)
24
Andamento del gettito e ciclo economico
 “… actually observed tax revenue developments are not only
determined by policy and decision making processes. They are
also substantially influenced by factors outside the decision
makers' sphere of (direct) influence. Predominant among these
other factors impacting on revenue developments are cyclical
influences on economic activity. Usually, in a favourable
economic climate (company) profits increase and new jobs are
created, both of which increase revenues from direct taxes,
namely corporate and personal income taxes. Generally,
accelerating job creation also means more people being liable to
social security contributions, hence increasing revenues of the
latter. Conversely, economic downturns are characterised by a
deterioration of company profits and only moderate wage
developments if not the loss of numerous jobs. Hence, tax and
social security revenues based on these macroeconomic
variables decrease disproportionately. (Taxation trends,….)
25
Gettito corretto per il ciclo: cosa è?
 Summing up, economic fluctuations – being only temporary
in nature – have an important impact on the assessment in
tax revenue developments. Nominal or observed tax
revenues are the result of two factors: temporary and
permanent ones. Hence, filtering out, to the extent possible,
the impact of cyclical - and hence temporary – factors from
permanent developments reveals important information to
policy makers and policy assessors. assessments of this
kind are usually based on correcting nominal tax revenue
developments for the economic cycle. The resulting
cyclically adjusted tax revenue data show primarily the
development of the structural components, which are
largely the result of discretionary fiscal policy decisions.
 In a nutshell, cyclically adjusted revenues in % of GDP for
each country (CAR) are derived as the (i) overall tax-to GDP
ratio (including social security contributions) (R) minus (ii)
the cyclical component of the tax revenues in % of GDP
(including social security contributions) (C).
CAR = R − C
26
Gettito corretto per il ciclo: come si misura
The cyclical component of tax revenues (C) is hence that part of
revenue which is due to cyclical developments. In order to determine
(C) two measures are necessary:
 First, a measure of the cyclical position of the economy has to be
derived, measuring the deviation of GDP from its "normal" level, i.e.
the level that would have been achieved if GDP growth was on its
"normal" path over time. In this report, the cyclical position is
provided by the HP – filtered output gap, i.e. the difference between
actual real GDP and a measure of the trend real GDP.
 …second measure - the tax revenue sensitivity. The tax revenue
sensitivity is defined as the percent change in tax revenues (as a
ratio to GDP) in reaction to a 1 % change in the output gap.
 The cyclical component of tax revenues (C) is hence calculated as
the product of the HP-filtered output gap and the tax revenue
sensitivity.
 By subtracting the cyclically determined part of tax revenues (C)
from overall tax revenues we arrive at the cyclically adjusted or
"structural“ tax revenues, highlighting the effects of discretionary
policy action on tax revenues.
27
Gettito corretto per il ciclo: risultati
 ….the cyclical component of tax revenues was not very pronounced
in the period under investigation. The cyclical component only
exceeded one percent of GDP at the end of the period in 2007 and
2008, when actual GDP was considerably above its potential,
translating into a high positive output gap. This generally low
cyclical component just reflects the rather limited reaction of tax
revenues to economic activity, as the tax revenue sensitivity is 0.42
for the Euro area [0,49 per Italia] and 0.39 for the EU-25 respectively.
In general, the development of the cyclical component for the Euro
area and the EU-25 are very similar. However, while the cyclical
component was more pronounced for the Euro area at the beginning
of the period, it showed higher values for the EU-25 from 2004
onwards. This is the result of faster recovery since 2004 and much
higher GDP growth since then for the new Member States.
 …. Comparing cyclically adjusted tax revenues (dashed lines) with
actual tax revenues unveils interesting tax trends that are masked by
the economic cycle. The high tax burden observed in 1995-1999 was
actually realised against the backdrop of unfavourable economic
conditions, resulting in an even higher tax burden in cyclically
adjusted terms……
28
Aliquote effettive e altri indicatori
 T/PIL e Ti/T sono indicatori aggregati e poco utili (il
loro andamento dipende da molteplici fattori)
 Anche aliquote legali da sole non bastano
 Indicatori più utili, che tengono conto
dell’interazione fra aliquote e basi imponibili:
 Backward looking o forward looking
 Micro o macro
 Esempi:
 Implicit tax rates (EU trends)
 Cuneo di imposta sul lavoro (OECD: taxing wages)
 EMTR e EATR sul capitale (vedi II modulo)
29
Aliquote macroeconomiche implicite (EU trends…)
 The tax-to-GDP ratio and the breakdown of tax revenues into
standard categories such as direct taxes, indirect taxes and
social contributions provide a first insight into cross-country
differences in terms of tax levels and its composition in terms
of tax type. This information is, however, already available
from the National Statistical Offices. This publication
additionally provides a broad classification of taxation in
three economic functions - consumption, labour and capital.
The report contains data on the absolute level of taxation by
economic function and computes implicit tax rates or ITRs,
i.e. average effective tax burden indicators; unlike simple
measures of the tax revenue, these take into account the size
of the potential tax base, which often differs substantially
from one country to the other. The methodology utilised in
this survey is discussed in detail in Annex B. (si veda
soprattutto parte D p.400)
30
Aliquote macroeconomiche implicite : metodologia
The tax revenue relative to GDP statistics presented in this
survey can be described as macro backward-looking tax
burden indicators. In Part C the taxes raised on economic
functions are shown as percentages of total GDP. However,
the consideration of tax revenue as a proportion of GDP
provides limited information as no insight is given as to
whether, for example, a high share of capital taxes in GDP is a
result of high tax rates or a large capital tax base. These
issues are tackled through the presentation of ITRs which do
not suffer from this shortcoming. ITRs measure the actual or
effective average tax burden directly or indirectly levied on
different types of economic income or activities that could
potentially be taxed by Member States.
31
Aliquote macroeconomiche implicite : metodologia
 Note, however, that the final economic incidence of the burden of
taxation can often be shifted from one taxpayer to another through
the interplay of demand and supply: a typical example is when firms
increase sales prices in response to a hike in corporate income
taxation; to a certain extent the firms' customers end up bearing part
of the increased tax burden. The ITRs cannot take these effects into
account, as this can only be done within a general equilibrium
framework. Despite this limitation, ITRs allow the monitoring of tax
burden levels over time (enabling the identification of shifts between
the taxation of different economic functions e.g. from capital to
labour) and across countries.
 Alternative measures of effective tax rates exist, which, using tax
legislation, simulate the tax burden generated by a given tax, and
can be linked to individual behaviour. However, these 'forwardlooking' effective tax rates do not allow the comparison of the tax
burden implied by different taxes; nor do they facilitate the
identification of shifts in the taxation of different economic income
and activities.
32
Aliquote macroeconomiche implicite: vantaggi
 For capital, an average tax rate is estimated by dividing all
taxes on capital by a broad approximation of the total capital
and business income both for households and corporations.
 For labour, an average tax rate is estimated by dividing direct
and indirect taxes on labour paid by employers and
employees by the total compensation of employees.
 The attractiveness of the approach lies in the fact that all
elements of taxation are implicitly taken into account, such as
the combined effects of statutory rates, tax deductions and
tax credits. They also include the effects due to the
composition of income, or companies' profit distribution
policies. Further, the effects of tax planning, as well as the tax
relief available (e.g. tax bases which are exempted below a
certain threshold, non-deductible interest expenses), are also
taken implicitly into account.
33
Aliquote macroeconomiche implicite: limiti
 The advantage of the ITRs in capturing a wide set of
influences on taxation is accompanied by difficulties in
interpreting the trends when a complete and precise
separation of the different forces of influence is not
possible. In addition, any timing differences that arise
because of lags in tax payments and business-cycle
effects may give rise to significant volatility in these
measures. In short, they represent a reduced model of all
variables influencing taxation, tax rates and bases.
34
Aliquote macroeconomiche implicite: andamento
 Data for the ITR on consumption, our preferred measure of the
effective tax burden, show that effective taxation of consumption,
which had been on an uptrend since 2001, dropped sharply in 2008.
The EU-27 arithmetic average declined by 0.7 percentage points that
year, the sharpest fall in a single year on record. Nevertheless, given
the previous relatively strong growth since 2001, the indicator still
exceeds its 2000 level by 0.6 points in 2008. This sharp and broad
drop cannot be attributed to declines in VAT rates …, and seem
therefore rather attributable to the first effects of the crisis on
consumption behaviour. The extent and rapidity of this development
is striking given that the ITR on consumption should arguably, by
construction, show a lesser susceptibility to cyclical developments
than other ITRs …. The sharpness of the drop is therefore probably
the result of a combination of factors, such as a shift in
consumption patterns towards primary goods, typically subject to
lower VAT rates, or involuntary inventory build-ups by businesses,
which due to the severity of the downturn at the end of 2008 might
have led to significant VAT refunds by tax administrations.
35
Aliquote macroeconomiche implicite: andamento
 Despite a wide consensus on the desirability of lower taxes on
labour, the levels of the ITR on labour confirm the widespread
difficulty in achieving this aim. Although the tax burden on
labour is off the peaks reached around the turn of the century,
the downward trend essentially came to a halt in the euro area
as several countries witnessed increases in the last few years.
Unlike for the ITR on consumption, the crisis did not induce
any visible reduction of the ITR on labour in 2008, possibly
because of the tendency for labour markets to lag behind
cyclical developments. The EU-25 average remained constant
and the euro area even recorded an increase in the ITR on
labour…..
36
Aliquote macroeconomiche implicite: andamento
 The ITR on capital shows a stronger decline for 2008, 0.7 points in the
EU-25 average, but this level remains the second highest on record
after the 2007 figure. Various factors suggest that, barring
introduction of new taxes, the ITR on capital is unlikely to remain at
these high levels in the next few years. First, the ITR on capital has
historically been sensitive to the business cycle: the EU-25 ITR on
capital reached a peak between 1999 and 2000, then declined, and
picked up again, in line with the business cycle. Inevitably, given the
in-built lag in CIT payments, the effects of the recession will
increasingly affect the ITR already in the short term. In addition, the
strong cuts in the CIT statutory rate should increasingly translate in
lower revenues.
 …The absolute levels of the ITRs on capital differ widely within the
EU, ranging from 45.9 % in the UK to a mere 10.7 % in Estonia.
37
Aliquote macroeconomiche implicite: andamento
 The development of environmental tax revenue is currently subject to
opposite forces; on the one hand, policymakers give high priority to
environmental protection, a trend which may grow even stronger as
attention focuses on the threat from global warming; on the other,
greater reliance on policy instruments other than taxes, such as
emissions trading, and growing political pressure to accommodate
the strong increases in the oil price recorded in the last few years by
reducing taxation of energy.
 Currently, roughly one euro out of every fourteen in revenue is raised
from environmental taxes.
 The implicit tax rate on energy shows that wide differences in the tax
revenue raised per unit of energy consumed persist (the highest
taxing country levies four times as much revenue per unit of energy
than the least taxing Member State), and indicates that in the
weighted average, once adjusted for inflation, taxation of energy has
been gradually declining.
38
Cuneo di imposta sul lavoro
 Labour tax wedge: Forward looking micro indicator
 OECD, Taxing Wages
http://www.oecd.org/document/34/0,3343,en_2649_345
33_44993442_1_1_1_37427,00.html
 Taxing Wages provides estimates of tax burdens
and of the tax wedge between labour costs and net
take-home pay
 Table O.1 presents the total tax wedge between total labour costs to
the employer and the corresponding net take-home pay for single
workers without children at average earnings levels in 2009 and
analyses the change in the tax wedge between 2008 and 2009 for all
OECD countries. The tax wedge varied widely across OECD countries
(column 1): it exceeded 50 per cent in Belgium, Hungary and
Germany and was lower than 20 per cent in Korea, New Zealand and
Mexico.
39
40
Cuneo di imposta sul lavoro:
un approfondimento per l’Italia
(Giannini, Guerra, 2010)
Non vi è dubbio che in Italia il cuneo di imposta sul lavoro,
misurato come divario percentuale fra costo del lavoro per
l’imprenditore e salario netto per il lavoratore, sia elevato,
anche in relazione ai nostri principali partner. Nell’effettuare
confronti internazionali, occorre però tenere sempre in
considerazione le modalità di erogazione e finanziamento degli
interventi nel campo del welfare e del sostegno ai bisogni
familiari. Ad esempio, mentre nel calcolo del cuneo di imposta
sul lavoro si tiene conto dei contributi che finanziano i sistemi
pensionistici pubblici, altrettanto non accade per i contributi
che finanziano i sistemi previdenziali privati di tipo
complementare. Ancora, se in un paese il sostegno alle
famiglie avviene attraverso l’offerta di servizi, ad accesso
gratuito, questo non si rifletterà in modo positivo sul cuneo
come accade per un trasferimento monetario, di cui si tiene
invece solitamente conto nel calcolo del cuneo stesso.
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Oltre ad essere sensibile alle varie componenti del prelievo,
fiscale e contributivo, che vengono incluse nel calcolo e che
possono variare da paese a paese, la misura del cuneo
dipende anche dalla figura e dal reddito preso a riferimento,
essendo esso in buona parte composto da imposte e
trasferimenti personali e progressivi.
Pur con queste precisazioni, non vi è dubbio che in Italia le
retribuzioni nette siano relativamente basse e, a causa del
cuneo fiscale e contributivo, il costo del lavoro relativamente
alto. Secondo l’ultimo rapporto dell’Oecd [2009] Taxing wages
2007-2008 – che ricostruisce i cunei di imposta sul salario
come rapporto fra imposte e contribuiti, al netto dei
trasferimenti monetari alle famiglie, in percentuale del costo
del lavoro – per un lavoratore con retribuzione media, con
coniuge e due figli a carico, il cuneo di imposta nel 2008 è il
36% in Italia, rispetto ad una media Oecd del 27,3% e dei paesi
Ue del 32%. Vi è comunque moltissima variabilità, che riflette
anche i fattori istituzionali precedentemente ricordati e nella
Ue (fra i 19 paesi considerati dall’Oecd) l’Italia ha una
posizione mediana, essendo superata da ben 9 paesi su 19.
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Tuttavia, a riprova delle difficoltà di confrontare questi
indicatori, va sottolineato che l’Oecd non tiene conto, nei
calcoli del cuneo, della presenza dell’Irap, che pure ha,
tra le componenti della sua base imponibile, la
remunerazione del fattore lavoro e su cui peraltro si è
concentrata la maggiore attenzione, nel dibattito di
policy. Se si tiene compiutamente conto dell’Irap, incluso
il fatto che essa è indeducibile dall’Ires, il cuneo aumenta
di un paio di punti percentuali.
43
44
45
….. se la normativa non fosse cambiata, il cuneo sarebbe
cresciuto automaticamente, proprio per effetto dell’operare
congiunto di fiscal drag e fiscal dividend. L’effetto è
maggiore per un contribuente con coniuge e figli a carico,
data la presenza, in questo caso, di detrazioni o deduzioni
e trasferimenti per oneri familiari, decrescenti al crescere
del reddito nominale. Confrontando il cuneo di imposta a
legislazione 2000 con quello osservato in base alla
normativa vigente ogni anno, è evidente come le numerose
normative che si sono susseguite nel periodo, abbiano
avuto solo l’effetto di compensare, un po’ meno per un
single, un po’ più per un contribuente con familiari a
carico, gli effetti automatici legati al fiscal drag e al fiscal
dividend… “
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Testi di riferimento

OECD, Revenue Statistics 1965-2008, 2009 Edition
http://www.oecd.org/document/4/0,3343,en_2649_34533_414074
28_1_1_1_1,00.html
Eurostat and European Commission, Taxation trends in the
European Union, 2010 edition
http://ec.europa.eu/taxation_customs/resources/documents/tax
ation/gen_info/economic_analysis/tax_structures/2010/2010_ful
l_text_en.pdf
Altre letture:






S. Loretz, Corporate taxation in the OECD in a wider context, Oxford
Review of Economic Policy, Volume 24, Number 4, 2008, pp.639–660.
Becker, J., Elsayyad, M. 2009. The evolution and convergence of OECD tax
systems, Intereconomics: review of European economic policy, 44 2,
pp105-113
OECD, Taxing wages, 2009
http://www.oecd.org/document/34/0,3343,en_2649_34533_44993442_1_1_1_
37427,00.html
S.Giannini e M.C.Guerra, Un decennio di fisco: poche riforme e molte
occasioni mancate, in M.C.Guerra, A. Zanardi, Rapporto finanza pubblica,
2010, Il Mulino, 2010.
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