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Why is There Corporate Taxation in a Small Open Economy? The Role of Transfer Pricing and Income Shifting Author info | Abstract | Publisher info | Download info | Related research | Statistics Roger H. Gordon
Jeffrey K. Mackie-Mason
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Several recent papers argue that corporate income taxes should not be used by small, open economies. With capital mobility, the burden of the tax falls on fixed factors (e.g., labor), and the tax system is more efficient if labor is taxed directly. However, corporate taxes not only exist but rates are roughly comparable with the top personal tax rates. Past models also forecast that multinationals should not invest in countries with low corporate tax rates, since the surtax they owe when profits are repatriated puts them at a competitive disadvantage. Yet such foreign direct investment is substantial. We suggest that the resolution of these puzzles may be found in the role of income shifting, both domestic (between the personal and corporate tax bases) and cross-border (through transfer pricing). Countries need nondistortionary corporate taxes as a backstop to labor taxes to discourage individuals from converting their labor income into otherwise untaxed corporate income. The optimal corporate and labor tax rates are equal. We also explore some other effects that domestic and cross-border income shifting have on optimal tax design.
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Paper provided by Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics in its series EPRU Working Paper Series with number
93-06.
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Paper Roger H. Gordon & Jeffrey K. MacKie-Mason, 1994.
"Why Is There Corporate Taxation In a Small Open Economy? The Role of Transfer Pricing and Income Shifting ,"
NBER Working Papers
4690, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted) Gordon, R.H. & Mackie-Mason, J.K., 1993.
"Why is There Corporate Taxation in a Small Open Econom? The Role of Transfer Pricing and Income Shifting ,"
Memorandum
18/1993, Oslo University, Department of Economics.
Chapter References listed on IDEAS Please 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.: Gordon, Roger H, 1992.
" Can Capital Income Taxes Survive in Open Economies? ,"
Journal of Finance ,
American Finance Association, vol. 47(3), pages 1159-80, July.
[Downloadable!] (restricted)
Other versions: Assaf Razin & Efraim Sadka, 1991.
"International Tax Competition and Gains from Tax Harmonization ,"
NBER Working Papers
3152, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions: Hirshleifer, Jack, 1971.
"The Private and Social Value of Information and the Reward to Inventive Activity ,"
American Economic Review ,
American Economic Association, vol. 61(4), pages 561-74, September.
[Downloadable!] (restricted)
Roger H. Gordon & Jeffrey K. MacKie-Mason, 1992.
"Tax Distortions to the Choice of Organizational Form ,"
NBER Working Papers
4227, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Gordon, R.H. & Mackie-Mason, J.K., 1993.
"Tax Distorsions to the Choice of Organizational Form ,"
Memorandum
21/1993, Oslo University, Department of Economics.
Roger H. Gordon & Jeffrey K. MacKie--Mason, 1994.
"Tax Distortions to the Choice of Organizational Form ,"
Public Economics
9401004, EconWPA, revised 18 Jan 1994.
[Downloadable!] Gordon, Roger H. & MacKie-Mason, Jeffrey K., 1994.
"Tax distortions to the choice of organizational form ,"
Journal of Public Economics ,
Elsevier, vol. 55(2), pages 279-306, October.
[Downloadable!] (restricted) Martin Feldstein & Charles Horioka, 1980.
"Domestic Savings and International Capital Flows ,"
NBER Working Papers
0310, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions: Roger H. Gordon & Joel Slemrod, 1988.
"Do We Collect Any Revenue from Taxing Capital Income? ,"
NBER Chapters ,
in: Tax Policy and the Economy: Volume 2, pages 89-130
National Bureau of Economic Research, Inc.
[Downloadable!]
Gravelle, Jane G & Kotlikoff, Laurence J, 1989.
"The Incidence and Efficiency Costs of Corporate Taxation When Corporate and Noncorporate Firms Produce the Same Good ,"
Journal of Political Economy ,
University of Chicago Press, vol. 97(4), pages 749-80, August.
[Downloadable!] (restricted)
Other versions: Auerbach, Alan J, 1983.
"Taxation, Corporate Financial Policy and the Cost of Capital ,"
Journal of Economic Literature ,
American Economic Association, vol. 21(3), pages 905-40, September.
[Downloadable!] (restricted)
Other versions: Gary S. Becker, 1968.
"Crime and Punishment: An Economic Approach ,"
Journal of Political Economy ,
University of Chicago Press, vol. 76, pages 169.
[Downloadable!] (restricted)
Other versions: James R. Hines, Jr. & R. Glenn Hubbard, 1990.
"Coming Home to America: Dividend Repatriations by U.S. Multinationals ,"
NBER Working Papers
2931, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Hines, J.R.J. & Hubbard, R.G., 1989.
"Coming Home To America - Devidend Repatriations By U.S. Multinationals ,"
Papers
146, Princeton, Woodrow Wilson School - Public and International Affairs.
James R. Hines, Jr. & R. Glenn Hubbard, 1990.
"Coming Home To America: Dividend Repatriations By U.S. Multinationals ,"
NBER Chapters ,
in: Taxation in the Global Economy, pages 161-208
National Bureau of Economic Research, Inc.
[Downloadable!] Jeffrey K. MacKie-Mason & Roger H. Gordon, 1991.
"How Much Do Taxes Discourage Incorporation ,"
NBER Working Papers
3781, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Jeffrey K. MacKie-Mason & Roger H. Gordon, 1994.
"How Much Do Taxes Discourage Incorporation? ,"
Public Economics
9401002, EconWPA.
[Downloadable!] Mackie-Mason, Jeffrey K & Gordon, Roger H, 1997.
" How Much Do Taxes Discourage Incorporation? ,"
Journal of Finance ,
American Finance Association, vol. 52(2), pages 477-505, June.
[Downloadable!] (restricted) Polinsky, Mitchell & Shavell, Steven, 1979.
"The Optimal Tradeoff between the Probability and Magnitude of Fines ,"
American Economic Review ,
American Economic Association, vol. 69(5), pages 880-91, December.
[Downloadable!] (restricted)
Hines, J.R. & Rice, E.M., 1990.
"Fiscal Paradise: Foreign Tax Havens And American Business ,"
Papers
56, Princeton, Woodrow Wilson School - Discussion Paper.
Other versions:
James R. Hines, Jr. & Eric M. Rice, 1994.
"Fiscal Paradise: Foreign Tax Havens and American Business ,"
NBER Working Papers
3477, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted) Hines, James R, Jr & Rice, Eric M, 1994.
"Fiscal Paradise: Foreign Tax Havens and American Business ,"
The Quarterly Journal of Economics ,
MIT Press, vol. 109(1), pages 149-82, February.
[Downloadable!] (restricted) Roger H. Gordon & A. Lans Bovenberg, 1994.
"Why is Capital so Immobile Internationally?: Possible Explanations and Implications for Capital Income Taxation ,"
NBER Working Papers
4796, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Gordon, R.H. & Bovenberg, A.L., 1994.
"Why Is Capital So Immobile Internationally?: Possible Explanations and Implications for Capital Income Taxation ,"
Working Papers
358, Research Seminar in International Economics, University of Michigan.
Gordon, Roger H & Bovenberg, A Lans, 1996.
"Why Is Capital So Immobile Internationally? Possible Explanations and Implications for Capital Income Taxation ,"
American Economic Review ,
American Economic Association, vol. 86(5), pages 1057-75, December.
[Downloadable!] (restricted) Harry Grubert & Joel Slemrod, 1994.
"The Effect of Taxes on Investment and Income Shifting to Puerto Rico ,"
NBER Working Papers
4869, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Full
references Cited by : (explanations , Please 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.)
James R. Hines, Jr., 1996.
"Tax Policy and the Activities of Multinational Corporations ,"
NBER Working Papers
5589, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Stöwhase, Sven, 2004.
"Asymmetric Capital Tax Competition with Profit Shifting ,"
Discussion Papers in Economics
454, University of Munich, Department of Economics.
[Downloadable!]
Other versions: Harry Grubert, 2000.
"Tax Planning by Companies and Tax Competition by Governments: Is There Evidence of Changes in Behavior? ,"
NBER Chapters ,
in: International Taxation and Multinational Activity, pages 113-142
National Bureau of Economic Research, Inc.
[Downloadable!]
Vidar Christiansen & Matti Tuomala, 2008.
"On taxing capital income with income shifting ,"
International Tax and Public Finance ,
Springer, vol. 15(4), pages 527-545, August.
[Downloadable!] (restricted)
Gordon H. HANSON, 2001.
"Should Countries Promote Foreign Direct Investment? ,"
G-24 Discussion Papers
9, United Nations Conference on Trade and Development.
[Downloadable!]
Joel Slemrod & John D. Wilson, 2006.
"Tax Competition With Parasitic Tax Havens ,"
NBER Working Papers
12225, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Roger H. Gordon & James R. Hines Jr., 2002.
"International Taxation ,"
NBER Working Papers
8854, National Bureau of Economic Research, Inc.
[Downloadable!] (restricted)
Other versions:
Gordon, Roger H. & Hines, James Jr, 2002.
"International taxation ,"
Handbook of Public Economics ,
in: A. J. Auerbach & M. Feldstein (ed.), Handbook of Public Economics, edition 1, volume 4, chapter 28, pages 1935-1995
Elsevier.
[Downloadable!] (restricted)
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