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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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References

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Citations

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Cited by:
  1. Michaël Zemmour, 2012. "Tax competition and the move from insurance to assistance," Documents de travail du Centre d'Economie de la Sorbonne 12090r, Université Panthéon-Sorbonne (Paris 1), Centre d'Economie de la Sorbonne, revised Mar 2013.
  2. Karkinsky, Tom & Riedel, Nadine, 2012. "Corporate taxation and the choice of patent location within multinational firms," Journal of International Economics, Elsevier, vol. 88(1), pages 176-185.
  3. Dischinger, Matthias & Riedel, Nadine, 2008. "Corporate Taxes and the Location of Intangible Assets Within Multinational Firms," Discussion Papers in Economics 5294, University of Munich, Department of Economics.
  4. 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.
  5. Christoph Ernst & Katharina Richter & Nadine Riedel, 2013. "Corporate taxation and the quality of research & development," Working Papers 1301, Oxford University Centre for Business Taxation.
  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. 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.
  8. 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.
  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. Fuest, Clemens & Spengel, Christoph & Finke, Katharina & Heckemeyer, Jost H. & Nusser, Hannah, 2013. "Profit shifting and 'aggressive' tax planning by multinational firms: Issues and options for reform," ZEW Discussion Papers 13-078, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
  11. Dan Andrews & Chiara Criscuolo, 2013. "Knowledge-Based Capital, Innovation and Resource Allocation," OECD Economics Department Working Papers 1046, OECD Publishing.
  12. 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.

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