Although both concepts represent concessions in relation to a certain benchmark tax,
the definition of the benchmark might differ in each approach, given that each approach is
guided by different principles. Therefore, whereas a “tax incentive” is defined by the
objective which its application is designed to pursue, a “tax expenditure” is defined by
measurement in terms of resource allocation and, therefore, in spite of the coincidence of
both being identified as counterparts to a benchmark tax, there are certain tax incentives that
cannot be classed as tax expenditures, and vice versa. An example of this might be the way
that dividends paid abroad have been treated as part of a comprehensive income tax
definition, resulting in their computation as negative tax expenditures. At the same time, the
distance between these two concepts also depends on the normative scope of the criterion by
which the framework for tax expenditure definition is generally defined. In this sense, insofar
as these concessions are contrasted against a narrow definition of the benchmark, which is
itself close to the general existing tax code, might mean that there are tax incentives that
cannot be identified as tax expenditures, because they are themselves included within the tax
regulations, in spite of the fact that the concession’s economic effects do not effectively
represent a stimulus towards a certain behavior.