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Tax Spillovers under Separate accounting and Formula Apportionment

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  • Nielsen, Soren Bo
  • Raimondos-Møller, Pascalis
  • Schjelderup, Guttorm

Abstract

It is observed in the real world that taxes matter for location decisions and that multinationals shift profits by transfer pricing. The US and Canada use Formula Apportionment (FA) to tax corporate income, and the EU is debating a switch from Separate Accounting (SA) to FA. This paper develops a theoretical model that compares basic properties of FA to SA. The focal point of the analysis is on how changes in tax rates affect capital formation, input choice, and transfer pricing as well as spillovers on tax revenue in other countries. The analysis shows that a move from SA to FA will not eliminate such spillovers and will, in cases identified in the paper, actually aggravate them.

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Bibliographic Info

Paper provided by C.E.P.R. Discussion Papers in its series CEPR Discussion Papers with number 2831.

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Date of creation: Jun 2001
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Handle: RePEc:cpr:ceprdp:2831

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Related research

Keywords: Formula Apportionment; Separate Accounting; Tax Externalities; Transfer Prices;

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Cited by:
  1. Rüdiger Pethig & Andreas Wagener, 2003. "Profit Tax Competition and Formula Apportionment," Volkswirtschaftliche Diskussionsbeiträge 106-03, Universität Siegen, Fakultät Wirtschaftswissenschaften, Wirtschaftsinformatik und Wirtschaftsrecht.
  2. Egger, Peter & Eggert, Wolfgang & Keuschnigg, Christian & Winner, Hannes, 2010. "Corporate taxation, debt financing and foreign-plant ownership," European Economic Review, Elsevier, vol. 54(1), pages 96-107, January.
  3. Eggert, Wolfgang & Haufler, Andreas, 2006. "Company tax coordination cum tax rate competition in the European Union," Discussion Papers in Economics 902, University of Munich, Department of Economics.
  4. Joann Martens Weiner, 2005. "Formulary Apportionment and Group Taxation in the European Union: Insights from the United States and Canada," Taxation Papers 8, Directorate General Taxation and Customs Union, European Commission, revised Mar 2005.
  5. Clemens Fuest, 2008. "The European Commission´s Proposal for a Common Consolidated Corporate Tax Base," Working Papers 0823, Oxford University Centre for Business Taxation.
  6. Ana Agundez-Garcia, 2006. "The Delineation and Apportionment of an EU Consolidated Tax Base for Multi-jurisdictional Corporate Income Taxation: a Review of Issues and Options," Taxation Papers 9, Directorate General Taxation and Customs Union, European Commission, revised Oct 2006.
  7. Kind, Hans Jarle & Midelfart, Karen Helene & Schjelderup, Guttorm, 2005. "Corporate tax systems, multinational enterprises, and economic integration," Journal of International Economics, Elsevier, vol. 65(2), pages 507-521, March.
  8. Charles E. Hyde, 2001. "Multinationals And The Relationship Between Strategic And Tax Transfer Prices," Department of Economics - Working Papers Series 822, The University of Melbourne.
  9. Thiess Buettner & Nadine Riedel & Marco Runkel, 2008. "Strategic Consolidation under Formula Apportionment," CESifo Working Paper Series 2484, CESifo Group Munich.
  10. Kind, Hans Jarle & Schjelderup, Guttorm & Ulltveit-Moe, Karen-Helene, 2001. "Corporate Taxation, Multinational Enterprise and Economic Integration," CEPR Discussion Papers 2753, C.E.P.R. Discussion Papers.
  11. Peter Sørensen, 2004. "Company Tax Reform in the European Union," International Tax and Public Finance, Springer, vol. 11(1), pages 91-115, January.
  12. Haufler, Andreas, 2006. "Die Besteuerung multinationaler Unternehmen," Discussion Papers in Economics 1153, University of Munich, Department of Economics.
  13. Joann Weiner, 2002. "Formula Apportionment in the European Union: A Dream Come True or the EU’s Worst Nightmare?," CESifo Working Paper Series 667, CESifo Group Munich.
  14. Marcel Gérard & Joann Weiner, 2003. "Cross-Border Loss Offset and Formulary Apportionment: How do they affect multijurisdictional firm investment spending and interjurisdictional tax competition ?," CESifo Working Paper Series 1004, CESifo Group Munich.
  15. Doina Maria Radulescu, 2007. "From Separate Accounting to Formula Apportionment: Analysis in a Dynamic Framework," CESifo Working Paper Series 2122, CESifo Group Munich.
  16. Doina Maria Radulescu, 2002. "Besteuerung von Kapitalgesellschaften im Binnenmarkt - Reformvorschlag der Europäischen Kommission," Ifo Schnelldienst, Ifo Institute for Economic Research at the University of Munich, vol. 55(02), pages 12-18, 01.

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