Taxation of Outbound Direct Investment: Economic Principles and Tax Policy Considerations
Abstract
This paper reviews economic principles for optimality of the taxation of international profit, from both a global and national perspective. It argues that for traditional systems based on the residence of the investor or the source of the income, nothing less than full harmonisation across countries can achieve global optimality. The conditions for national optimality are more difficult to identify, but are most likely to imply source-based taxation. However, source-based taxation requires an allocation of the profits of multinational companies to individual jurisdictions; this is not only very difficult in practice, but in some cases is without any conceptual foundation. The taxation of interest income on a residence basis is also hard to justify if the aim of the tax system is to tax only the income arising from economic activity in a given country.Download Info
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Paper provided by Oxford University Centre for Business Taxation in its series Working Papers with number 0824.Length:
Date of creation: 2008
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Handle: RePEc:btx:wpaper:0824
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- Michael P. Devereux, 2008. "Taxation of outbound direct investment: economic principles and tax policy considerations," Oxford Review of Economic Policy, Oxford University Press, vol. 24(4), pages 698-719, winter.
- NEP-ALL-2008-10-13 (All new papers)
- NEP-PBE-2008-10-13 (Public Economics)
References
References listed on IDEASPlease report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
- Devereux, Michael P & Hubbard, R Glenn, 2003.
"Taxing Multinationals,"
International Tax and Public Finance,
Springer, vol. 10(4), pages 469-87, August.
- Michael P. Devereux & R. Glenn Hubbard, 2000. "Taxing Multinationals," NBER Working Papers 7920, National Bureau of Economic Research, Inc.
- Michael Keen & Hannu Piekkola, 1996.
"Simple rules for the optimal taxation of international capital income,"
IFS Working Papers
W96/18, Institute for Fiscal Studies.
- Keen, Michael & Piekkola, Hannu, 1997. " Simple Rules for the Optimal Taxation of International Capital Income," Scandinavian Journal of Economics, Wiley Blackwell, vol. 99(3), pages 447-61, September.
- Joseph E. Stiglitz & Partha Dasgupta, 1970.
"Differential Taxation, Public Goods, and Economic Efficiency,"
Cowles Foundation Discussion Papers
299, Cowles Foundation for Research in Economics, Yale University.
- Stiglitz, Joseph E & Dasgupta, P, 1971. "Differential Taxation, Public Goods and Economic Efficiency," Review of Economic Studies, Wiley Blackwell, vol. 38(114), pages 151-74, April.
- Huizinga, Harry & Nielsen, Soren Bo, 1997.
"Capital income and profit taxation with foreign ownership of firms,"
Journal of International Economics,
Elsevier, vol. 42(1-2), pages 149-165, February.
- Huizinga, H.P. & Nielsen, S.B., 1995. "Capital income and profits taxation with foreign ownership of firms," Discussion Paper 1995-82, Tilburg University, Center for Economic Research.
- Huizinga, H. & Nielsen, S.B., 1995. "Capital Income and Profits Taxation with Foreign Ownership of Firms," Papers 9582, Tilburg - Center for Economic Research.
- Harry Huizinga & Soeren Bo Nielsen, . "Capital Income and Profits Taxation with Foreign Ownerwhip of Firms," EPRU Working Paper Series 95-09, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
- Huizinga, H.P. & Nielsen, S.B., 1997. "Capital income and profit taxation with foreign ownership of firms," Open Access publications from Tilburg University urn:nbn:nl:ui:12-73857, Tilburg University.
- Devereux, Michael P & Griffith, Rachel, 2003.
"Evaluating Tax Policy for Location Decisions,"
International Tax and Public Finance,
Springer, vol. 10(2), pages 107-26, March.
- Devereux, Michael P & Griffith, Rachel, 2002. "Evaluating Tax Policy for Location Decisions," CEPR Discussion Papers 3247, C.E.P.R. Discussion Papers.
- Devereux, Michael P. & Pearson, Mark, 1995. "European tax harmonisation and production efficiency," European Economic Review, Elsevier, vol. 39(9), pages 1657-1681, December.
- Jeremy Edwards, 2005. "Gains from Trade in Government Revenue and Pareto-Efficient International Taxation," The B.E. Journal of Economic Analysis & Policy, De Gruyter, vol. 0(1), pages 22.
- MINTZ, Jacques & TULKENS , Henry, 1994.
"Optimality Properties of Alternative Systems of Taxation of Foreign Capital Income,"
CORE Discussion Papers
1994078, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
- Mintz, Jack & Tulkens, Henry, 1996. "Optimality properties of alternative systems of taxation of foreign capital income," Journal of Public Economics, Elsevier, vol. 60(3), pages 373-399, June.
- Michael P. Devereux & Christian Keuschnigg, 2009.
"The Distorting Arm’s Length Principle,"
Working Papers
0910, Oxford University Centre for Business Taxation.
- Devereux, Michael P. & Keuschnigg, Christian, 2009. "The Distorting Arm's Length Principle," CEPR Discussion Papers 7375, C.E.P.R. Discussion Papers.
- Christian Keuschnigg & Michael P. Devereux, 2009. "The Distorting Arm's Length Principle," University of St. Gallen Department of Economics working paper series 2009 2009-20, Department of Economics, University of St. Gallen.
- Michael P Devereux & Simon Loretz, 2008. "Increased efficiency through consolidation and formula apportionment in the European Union?," Working Papers 0812, Oxford University Centre for Business Taxation.
- Chiara Criscuolo & Ralf Martin, 2009.
"Multinationals and U.S. Productivity Leadership: Evidence from Great Britain,"
The Review of Economics and Statistics,
MIT Press, vol. 91(2), pages 263-281, May.
- Chiara Criscuolo & Ralf Martin, 2004. "Multinationals and U.S. Productivity Leadership: Evidence from Great Britain," OECD Science, Technology and Industry Working Papers 2004/5, OECD Publishing.
- Chiara Criscuolo & Ralf Martin, 2005. "Multinationals and US Productivity Leadership: Evidence from Great Britain," CEP Discussion Papers dp0672, Centre for Economic Performance, LSE.
- Stephen Bond & Alexander Klemm & Michael B. Devereux, 2007.
"The Effects of Dividend Taxes on Equity Prices: A Re-examination of the 1997 U.K. Tax Reform,"
IMF Working Papers
07/204, International Monetary Fund.
- Stephen R Bond & Michael P Devereux & Alexander Klemm, 2007. "The Effects of Dividend Taxes on Equity Prices: A Re-examination of the 1997 UK Tax Reform," Working Papers 0701, Oxford University Centre for Business Taxation.
- Mihir A. Desai, 2008. "The Decentering of the Global Firm," Harvard Business School Working Papers 09-054, Harvard Business School.
- Michael P. Devereux & Peter Birch Sørensen, 2006. "The Corporate Income Tax: international trends and options for fundamental reform," European Economy - Economic Papers 264, Directorate General Economic and Monetary Affairs (DG ECFIN), European Commission.
- Huizinga, Harry & Nielsen, Soren Bo, 2002.
"The coordination of capital income and profit taxation with cross-ownership of firms,"
Regional Science and Urban Economics,
Elsevier, vol. 32(1), pages 1-26, January.
- Huizinga, H.P. & Nielsen, S.B., 1996. "The Coordination of Capital Income and Profit Taxation with Cross-Ownership of Firms," Discussion Paper 1996-104, Tilburg University, Center for Economic Research.
- Harry Huizinga & Søren Bo Nielsen, . "The Coordination of Capital Income and Profit Taxation with Cross-Ownership of Firms," EPRU Working Paper Series 96-17, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
- Gordon, Roger H. & Bradford, David F., 1980.
"Taxation and the stock market valuation of capital gains and dividends : Theory and emphirical results,"
Journal of Public Economics,
Elsevier, vol. 14(2), pages 109-136, October.
- Roger H. Gordon & David F. Bradford, 1980. "Taxation and the stock market valuation of capital gains and dividends : Theory and emphirical results," NBER Chapters, in: Econometric Studies in Public Finance, pages 109-136 National Bureau of Economic Research, Inc.
- Johannes Becker & Clemens Fuest, 2007.
"Taxing Foreign Profits with International Mergers and Acquisitions,"
Working Papers
0719, Oxford University Centre for Business Taxation.
- Johannes Becker & Clemens Fuest, 2010. "Taxing Foreign Profits With International Mergers And Acquisitions," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 51(1), pages 171-186, 02.
- Alan Auerbach & Michael P. Devereux & Helen Simpson, 2007.
"Taxing Corporate Income,"
CESifo Working Paper Series
2139, CESifo Group Munich.
- Alan Auerbach & Michael P Devereux & Helen Simpson, 2007. "Taxing corporate income," Working Papers 0705, Oxford University Centre for Business Taxation.
- Alan J. Auerbach & Michael P. Devereux & Helen Simpson, 2008. "Taxing Corporate Income," NBER Working Papers 14494, National Bureau of Economic Research, Inc.
- Steve Bond & Michael Devereux, 1993.
"On the design of a neutral business tax under uncertainty,"
IFS Working Papers
W93/01, Institute for Fiscal Studies.
- Bonds, Stephen R. & Devereux, Michael P., 1995. "On the design of a neutral business tax under uncertainty," Journal of Public Economics, Elsevier, vol. 58(1), pages 57-71, September.
- Michael Keen & David Wildasin, 2004. "Pareto-Efficient International Taxation," American Economic Review, American Economic Association, vol. 94(1), pages 259-275, March.
- Horst, Thomas, 1980. "A Note on the Optimal Taxation of International Investment Income," The Quarterly Journal of Economics, MIT Press, vol. 94(4), pages 793-98, June.
- Michael Keen, 1993. "The welfare economics of tax co-ordination in the European Community : a survey," Fiscal Studies, Institute for Fiscal Studies, vol. 14(2), pages 15-36, February.
- Bond, Stephen R. & Devereux, Michael P., 2003.
"Generalised R-based and S-based taxes under uncertainty,"
Journal of Public Economics,
Elsevier, vol. 87(5-6), pages 1291-1311, May.
- Steve Bond & Michael Devereux, 1999. "Generalised R-based and S-based taxes under uncertainty," IFS Working Papers W99/09, Institute for Fiscal Studies.
- Michael P. Devereux, 2004. "Some Optimal Tax Rules for International Portfolio and Direct Investment," FinanzArchiv: Public Finance Analysis, Mohr Siebeck, Tübingen, vol. 60(1), pages 1-, April.
- Hutson, Elaine, 2007. "Mergers and acquisitions," Open Access publications from University College Dublin urn:hdl:10197/1981, University College Dublin.
- Joel Slemrod, 1994.
"Free-Trade Taxation and Protectionist Taxation,"
NBER Working Papers
4902, National Bureau of Economic Research, Inc.
- Joel Slemrod, 1995. "Free trade taxation and protectionist taxation," International Tax and Public Finance, Springer, vol. 2(3), pages 471-489, October.
- Bond, Stephen Roy & Devereux, Michael P, 2002. "Cash Flow Taxes in an Open Economy," CEPR Discussion Papers 3401, C.E.P.R. Discussion Papers.
Citations
Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.Cited by:
- Johannes Becker & Clemens Fuest, 2011.
"The taxation of foreign profits — The old view, the new view and a pragmatic view,"
Intereconomics: Review of European Economic Policy,
Springer, vol. 46(2), pages 92-97, March.
- Johannes Becker & Clemens Fuest, 2011. "The taxation of foreign profits - the old view, the new view and a pragmatic view," Working Papers 1104, Oxford University Centre for Business Taxation.
- Peter Egger & Valeria Merlo & Martin Ruf & Georg Wamser, 2012. "Consequences of the New UK Tax Exemption System: Evidence from Micro-level Data," CESifo Working Paper Series 3942, CESifo Group Munich.
- Johannes Becker, 2010. "Strategic Trade Policy through the Tax System," CESifo Working Paper Series 3066, CESifo Group Munich.
- Johannes Becker, 2009. "Taxation of Foreign Profits with Heterogeneous Multinational Firms," CESifo Working Paper Series 2899, CESifo Group Munich.
- Elschner, Christina & Heckemeyer, Jost Henrich & Spengel, Christoph, 2009. "Besteuerungsprinzipien und effektive Unternehmenssteuerbelastungen in der Europäischen Union," ZEW Discussion Papers 09-034, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
- Christina Elschner & Jost H. Heckemeyer & Christoph Spengel, 2011. "Besteuerungsprinzipien und effektive Unternehmenssteuerbelastungen in der Europäischen Union: Regelt sich die EU‐weite Steuerharmonisierung von selbst?," Perspektiven der Wirtschaftspolitik, Verein für Socialpolitik, vol. 12(1), pages 47-71, 02.
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