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Corporate Taxation and the Choice of Patent Location within Multinational Firms

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  • Tom Karkinsky

    ()
    (Oxford University Centre for Business Taxation)

  • Nadine Riedel

    ()
    (Oxford University Centre for Business Taxation, CESifo Munich)

Abstract

Corporate patents are perceived to be the key profit-drivers in many multinational enterprises (MNEs). Moreover, as the transfer pricing process for royalty payments is often highly intransparent, they also constitute a major source of profit shifting opportunities between multinational entities. For both reasons, MNEs have an incentive to locate their patents at affiliates with a relatively small corporate tax rate. Our paper empirically tests for this relationship by exploiting a unique dataset which links information on patent applications to micro panel data for European MNEs. Our results suggest that the corporate tax rate (differential to other group members) indeed exerts a negative effect on the number of patents filed by a subsidiary. The effect is quantitatively large and robust against controlling for affiliate size. The findings prevail if we additionally account for royalty withholding taxes. Moreover, binding `Controlled Foreign Company' rules tend to decrease the number of patent applications.

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Bibliographic Info

Paper provided by Oxford University Centre for Business Taxation in its series Working Papers with number 0931.

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Date of creation: 2009
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Handle: RePEc:btx:wpaper:0931

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Keywords: corporate taxation; multinational enterprise; profit shifting;

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Citations

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Cited by:
  1. Dischinger, Matthias & Riedel, Nadine, 2011. "Corporate taxes and the location of intangible assets within multinational firms," Journal of Public Economics, Elsevier, vol. 95(7), pages 691-707.
  2. Michaël Zemmour, 2012. "Tax competition and the move from insurance to assistance," Université Paris1 Panthéon-Sorbonne (Post-Print and Working Papers) halshs-00768909, HAL.
  3. Dhammika Dharmapala, 2014. "What Do We Know About Base Erosion and Profit Shifting? A Review of the Empirical Literature," CESifo Working Paper Series 4612, CESifo Group Munich.
  4. Dan Andrews & Chiara Criscuolo, 2013. "Knowledge-Based Capital, Innovation and Resource Allocation," OECD Economics Department Working Papers 1046, OECD Publishing.
  5. Lourdes Jerez Barroso, 2011. "Base imponible y neutralidad del Impuesto de Sociedades: alternativas y experiencias," Hacienda Pública Española, IEF, vol. 197(2), pages 113-146, June.
  6. Marchese, Carla & Marsiglio, Simone & Privileggi, Fabio & Ramello, Giovanni, 2014. "Endogenous Recombinant Growth through Market Production of Knowledge and Intellectual Property Rights," Department of Economics and Statistics Cognetti de Martiis. Working Papers 201413, University of Turin.
  7. Tom Karkinsky & Nadine Riedel, 2009. "Corporate Taxation and the Choice of Patent Location within Multinational Firms," CESifo Working Paper Series 2879, CESifo Group Munich.
  8. Evers, Maria Theresia & Meier, Ina & Spengel, Christoph, 2014. "Transparency in financial reporting: Is country-by-country reporting suitable to combat international profit shifting?," ZEW Discussion Papers 14-015, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
  9. Loretz, Simon & Mokkas, Socrates, 2013. "Evidence for profit shifting with tax sensitive capital stocks," Annual Conference 2013 (Duesseldorf): Competition Policy and Regulation in a Global Economic Order 79847, Verein für Socialpolitik / German Economic Association.
  10. Griffith, Rachel & Miller, Helen & O'Connell, Martin, 2011. "Corporate taxes and the location of intellectual property," CEPR Discussion Papers 8424, C.E.P.R. Discussion Papers.
  11. Fuest, Clemens & Spengel, Christoph & Finke, Katharina & Heckemeyer, Jost & Nusser, Hannah, 2013. "Profit shifting and 'aggressive' tax planning by multinational firms: Issues and options for reform," ZEW Discussion Papers 13-044, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
  12. Langenmayr, Dominika & Lester, Rebecca, 2014. "Taxation and Corporate Risk-Taking," Discussion Papers in Economics 20977, University of Munich, Department of Economics.
  13. Christoph Ernst & Katharina Richter & Nadine Riedel, 2013. "Corporate taxation and the quality of research & development," Working Papers 1301, Oxford University Centre for Business Taxation.
  14. Joel Stiebale, 2014. "Cross-Border M&As and Innovative Activity of Acquiring and Target Firms," Discussion Papers 2014-06, University of Nottingham, GEP.

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