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Corporate Taxation and the Choice of Patent Location within Multinational Firms

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Author Info
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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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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Related research
Keywords: corporate taxation; multinational enterprise; profit shifting;

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Find related papers by JEL classification:
H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion
C33 - Mathematical and Quantitative Methods - - Multiple or Simultaneous Equation Models; Multiple Variables - - - Models with Panel Data

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  3. Tom Karkinsky & Nadine Riedel, 2009. "Corporate Taxation and the Choice of Patent Location within Multinational Firms," Working Papers 0914, Oxford University Centre for Business Taxation. [Downloadable!]
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    Other versions:
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  13. Ethier, Wilfred J. & Markusen, James R., 1996. "Multinational firms, technology diffusion and trade," Journal of International Economics, Elsevier, vol. 41(1-2), pages 1-28, August. [Downloadable!] (restricted)
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  14. Luigi Zingales, 2000. "In Search of New Foundations," Journal of Finance, American Finance Association, vol. 55(4), pages 1623-1653, 08. [Downloadable!] (restricted)
  15. Alfons Weichenrieder, 2009. "Profit shifting in the EU: evidence from Germany," International Tax and Public Finance, Springer, vol. 16(3), pages 281-297, June. [Downloadable!] (restricted)
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  16. Fosfuri, Andrea, 2000. "Patent protection, imitation and the mode of technology transfer," International Journal of Industrial Organization, Elsevier, vol. 18(7), pages 1129-1149, October. [Downloadable!] (restricted)
  17. Zingales, Luigi, 2000. "In Search of New Foundations," CEPR Discussion Papers 2551, C.E.P.R. Discussion Papers. [Downloadable!] (restricted)
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