This thesis presents a comparative analysis of corporate taxation systems in the United States and the European Union, with a focus on Italy, to evaluate structural divergences, policy effectiveness, and their implications for corporate competitiveness and multinational investment strategies. Against a backdrop of global economic integration, intensified tax competition, and international initiatives to combat profit shifting and base erosion, the study employs a mixed methods approach that combines qualitative analysis of legislative frameworks with quantitative evaluation of investment trends. It systematically compares statutory and effective tax rates, anti-avoidance measures such as the U.S. GILTI, BEAT, and FDII, and the EU’s CCCTB, as well as administrative compliance complexities. By analyzing recent reforms including the U.S. Tax Cuts and Jobs Act (TCJA, 2017) and Italy’s IRES, IRAP, and Allowance for Corporate Equity (ACE), the research highlights how these regimes influence corporate investment behavior, profit allocation strategies, and jurisdictional attractiveness. Empirical findings reveal that while the TCJA’s territorial approach and rate reductions simplified the U.S. system and temporarily boosted domestic investment, persistent EU policy fragmentation and Italy’s administrative inefficiencies underscore unresolved challenges in harmonization and compliance. This study contributes to filling gaps in comparative empirical tax literature by linking structural tax design to firm level behavioral responses, particularly in cross border contexts. It concludes with policy recommendations to enhance transatlantic tax coordination, address compliance asymmetries, and promote fiscal sustainability in an era of evolving global tax governance.

This thesis presents a comparative analysis of corporate taxation systems in the United States and the European Union, with a focus on Italy, to evaluate structural divergences, policy effectiveness, and their implications for corporate competitiveness and multinational investment strategies. Against a backdrop of global economic integration, intensified tax competition, and international initiatives to combat profit shifting and base erosion, the study employs a mixed methods approach that combines qualitative analysis of legislative frameworks with quantitative evaluation of investment trends. It systematically compares statutory and effective tax rates, anti-avoidance measures such as the U.S. GILTI, BEAT, and FDII, and the EU’s CCCTB, as well as administrative compliance complexities. By analyzing recent reforms including the U.S. Tax Cuts and Jobs Act (TCJA, 2017) and Italy’s IRES, IRAP, and Allowance for Corporate Equity (ACE), the research highlights how these regimes influence corporate investment behavior, profit allocation strategies, and jurisdictional attractiveness. Empirical findings reveal that while the TCJA’s territorial approach and rate reductions simplified the U.S. system and temporarily boosted domestic investment, persistent EU policy fragmentation and Italy’s administrative inefficiencies underscore unresolved challenges in harmonization and compliance. This study contributes to filling gaps in comparative empirical tax literature by linking structural tax design to firm level behavioral responses, particularly in cross border contexts. It concludes with policy recommendations to enhance transatlantic tax coordination, address compliance asymmetries, and promote fiscal sustainability in an era of evolving global tax governance.

Comparative Analysis of Corporate Taxation Systems: United States vs. European Union (with special reference to Italy)

JAHANI MOGHADDAM, MOHAMMAD
2024/2025

Abstract

This thesis presents a comparative analysis of corporate taxation systems in the United States and the European Union, with a focus on Italy, to evaluate structural divergences, policy effectiveness, and their implications for corporate competitiveness and multinational investment strategies. Against a backdrop of global economic integration, intensified tax competition, and international initiatives to combat profit shifting and base erosion, the study employs a mixed methods approach that combines qualitative analysis of legislative frameworks with quantitative evaluation of investment trends. It systematically compares statutory and effective tax rates, anti-avoidance measures such as the U.S. GILTI, BEAT, and FDII, and the EU’s CCCTB, as well as administrative compliance complexities. By analyzing recent reforms including the U.S. Tax Cuts and Jobs Act (TCJA, 2017) and Italy’s IRES, IRAP, and Allowance for Corporate Equity (ACE), the research highlights how these regimes influence corporate investment behavior, profit allocation strategies, and jurisdictional attractiveness. Empirical findings reveal that while the TCJA’s territorial approach and rate reductions simplified the U.S. system and temporarily boosted domestic investment, persistent EU policy fragmentation and Italy’s administrative inefficiencies underscore unresolved challenges in harmonization and compliance. This study contributes to filling gaps in comparative empirical tax literature by linking structural tax design to firm level behavioral responses, particularly in cross border contexts. It concludes with policy recommendations to enhance transatlantic tax coordination, address compliance asymmetries, and promote fiscal sustainability in an era of evolving global tax governance.
2024
Comparative Analysis of Corporate Taxation Systems: United States vs. European Union (with special reference to Italy)
This thesis presents a comparative analysis of corporate taxation systems in the United States and the European Union, with a focus on Italy, to evaluate structural divergences, policy effectiveness, and their implications for corporate competitiveness and multinational investment strategies. Against a backdrop of global economic integration, intensified tax competition, and international initiatives to combat profit shifting and base erosion, the study employs a mixed methods approach that combines qualitative analysis of legislative frameworks with quantitative evaluation of investment trends. It systematically compares statutory and effective tax rates, anti-avoidance measures such as the U.S. GILTI, BEAT, and FDII, and the EU’s CCCTB, as well as administrative compliance complexities. By analyzing recent reforms including the U.S. Tax Cuts and Jobs Act (TCJA, 2017) and Italy’s IRES, IRAP, and Allowance for Corporate Equity (ACE), the research highlights how these regimes influence corporate investment behavior, profit allocation strategies, and jurisdictional attractiveness. Empirical findings reveal that while the TCJA’s territorial approach and rate reductions simplified the U.S. system and temporarily boosted domestic investment, persistent EU policy fragmentation and Italy’s administrative inefficiencies underscore unresolved challenges in harmonization and compliance. This study contributes to filling gaps in comparative empirical tax literature by linking structural tax design to firm level behavioral responses, particularly in cross border contexts. It concludes with policy recommendations to enhance transatlantic tax coordination, address compliance asymmetries, and promote fiscal sustainability in an era of evolving global tax governance.
Corporate Taxation
Tax Competitiveness
Profit Shifting
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Utilizza questo identificativo per citare o creare un link a questo documento: https://hdl.handle.net/20.500.12608/89486