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The Choice Of Apportionment Factors Under Formula Apportionment

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  • Marco Runkel
  • Guttorm Schjelderup

Abstract

This paper investigates the choice of apportionment factors under a corporate tax system of Formula Apportionment. In contrast to perceived wisdom, we show that the apportionment formula contains both mobile (capital) and immobile (labor) factors if jurisdictions are granted full fiscal autonomy with respect to tax rates and the formula design. A welfare gain can be realized by delegating the decision over apportionment factors to a central planner (centralization), while at the same time allowing jurisdictions fiscal autonomy in setting tax rates. However, the central planner uses the formula as a corrective instrument to internalize fiscal externalities and, therefore, uses mobile apportionment factors as well.
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  • Marco Runkel & Guttorm Schjelderup, 2011. "The Choice Of Apportionment Factors Under Formula Apportionment," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 52(3), pages 913-934, August.
    • Handle: RePEc:ier:iecrev:v:52:y:2011:i:3:p:913-934
    DOI: j.1468-2354.2011.00654.x
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    Cited by:

    1. Raymond Mataloni & Kim Ruhl & Dylan Rassier & Fatih Guvenen, 2016. "Offshore Profit Shifting and Domestic Productivity Measurement," 2016 Meeting Papers 1382, Society for Economic Dynamics.
    2. Mardan, Mohammed & Stimmelmayr, Michael, 2018. "Tax revenue losses through cross-border loss offset: An insurmountable hurdle for formula apportionment?," European Economic Review, Elsevier, vol. 102(C), pages 188-210.
    3. Martini, Jan-Thomas & Niemann, Rainer & Simons, Dirk, 2014. "Management incentives under formula apportionment: Tax-induced distortions of effort and compensation in a principal-agent setting," arqus Discussion Papers in Quantitative Tax Research 168, arqus - Arbeitskreis Quantitative Steuerlehre.
    4. Jennifer Bruner & Dylan G. Rassier & Kim J. Ruhl, 2018. "Multinational Profit Shifting and Measures throughout Economic Accounts," NBER Chapters, in: Challenges of Globalization in the Measurement of National Accounts, pages 153-205, National Bureau of Economic Research, Inc.
    5. Hines Jr., James R., 2010. "Income misattribution under formula apportionment," European Economic Review, Elsevier, vol. 54(1), pages 108-120, January.
    6. Ortmann, Regina & Pummerer, Erich, 2015. "Formula apportionment or separate accounting? Tax-induced distortions of multinationals' locational investment decisions," arqus Discussion Papers in Quantitative Tax Research 198, arqus - Arbeitskreis Quantitative Steuerlehre.
    7. Dietrich, Maik, 2009. "Entscheidungswirkungen einer europaweit harmonisierten Konzernbesteuerung [Impacts of European Group Taxation]," MPRA Paper 59870, University Library of Munich, Germany.
    8. Ruud De Mooij & Li Liu & Dinar Prihardini, 2021. "An Assessment of Global Formula Apportionment," National Tax Journal, University of Chicago Press, vol. 74(2), pages 431-465.
    9. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2017. "Formula apportionment: Factor allocation and tax avoidance," arqus Discussion Papers in Quantitative Tax Research 220, arqus - Arbeitskreis Quantitative Steuerlehre, revised 2017.
    10. Fatih Guvenen & Raymond J. Mataloni Jr. & Dylan G. Rassier & Kim J. Ruhl, 2022. "Offshore Profit Shifting and Aggregate Measurement: Balance of Payments, Foreign Investment, Productivity, and the Labor Share," American Economic Review, American Economic Association, vol. 112(6), pages 1848-1884, June.
    11. David R. Agrawal, 2023. "Hidden Havens: State and Local Governments as Tax Havens?," CESifo Working Paper Series 10573, CESifo.
    12. MIYOSHI Yoshiyuki, 2017. "Does Sales Factor Apportionment Benefit the Welfare of State?," Discussion papers 17124, Research Institute of Economy, Trade and Industry (RIETI).
    13. Gresik, Thomas A., 2016. "Allowing firms to choose between separate accounting and formula apportionment taxation," Journal of Public Economics, Elsevier, vol. 138(C), pages 32-42.
    14. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2015. "Formula apportionment: Factor allocation and tax avoidance," arqus Discussion Papers in Quantitative Tax Research 199, arqus - Arbeitskreis Quantitative Steuerlehre.
    15. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2015. "Formula apportionment: Factor allocation and tax avoidance," Discussion Papers 2015/30, Free University Berlin, School of Business & Economics.
    16. Dyreng, Scott D. & Lindsey, Bradley P. & Thornock, Jacob R., 2013. "Exploring the role Delaware plays as a domestic tax haven," Journal of Financial Economics, Elsevier, vol. 108(3), pages 751-772.
    17. Jan Thomas Martini & Rainer Niemann & Dirk Simons, 2014. "Management Incentives under Formula Apportionment - Tax-Induced Distortions of Effort and Compensation in a Principal-Agent Setting -," CESifo Working Paper Series 4908, CESifo.
    18. Sara L. McGaughey & Pascalis Raimondos, 2019. "Shifting MNE taxation from national to global profits: A radical reform long overdue," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 50(9), pages 1668-1683, December.
    19. Danuse NERUDOVA & Katerina KRCHNIVA, 2016. "Tax sharing under the Common Consolidated Corporate Tax Base: Measurement of the profit generating factors in the agriculture sector," Agricultural Economics, Czech Academy of Agricultural Sciences, vol. 62(8), pages 363-377.
    20. repec:dau:papers:123456789/6913 is not listed on IDEAS

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