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Sorting into Outsourcing: Are Profits Taxed at a Gorilla's Arm's Length?

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  • Bauer, Christian
  • Langenmayr, Dominika

Abstract

This article analyzes profit taxation according to the arm's length principle in a new model where heterogeneous firms sort into foreign outsourcing. We show that multinational firms are able to shift profits abroad even if they fully comply with the tax code. This is because, in equilibrium, intra-firm transactions occur in firms that are better than the market at input production. Transfer prices set at market values following the arm's length principle thus systematically exceed multinationals' marginal costs. This allows for a reduction of tax payments with each unit sold. The optimal organization of firms hence provides a new rationale for the empirically observed lower tax burden of multinational corporations.

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Bibliographic Info

Paper provided by University of Munich, Department of Economics in its series Discussion Papers in Economics with number 12312.

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Date of creation: Sep 2011
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Handle: RePEc:lmu:muenec:12312

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Keywords: outsourcing; profit taxation; transfer pricing; arm's length principle; multinational firms;

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Cited by:
  1. Johannes Becker & Ronald B. Davies, 2014. "A Negotiation-Based Model of Tax-Induced Transfer Pricing," The Institute for International Integration Studies Discussion Paper Series iiisdp451, IIIS.
  2. Bauer, Christian & Langenmayr, Dominika, 2011. "Sorting into Outsourcing: Are Pro ts Taxed at a Gorilla's Arm's Length?," Discussion Papers in Economics 12311, University of Munich, Department of Economics.
  3. Dominika Langenmayr & Andreas Haufler & Christian Josef Bauer, 2012. "Should Tax Policy Favor High- or Low-Productivity Firms?," CESifo Working Paper Series 4034, CESifo Group Munich.
  4. Christian J. Bauer & Dominika Langenmayr, 2011. "Sorting into Outsourcing: Are Profits Taxed at a Gorilla's Arm's Lenght?," Working Papers 104, Bavarian Graduate Program in Economics (BGPE).
  5. Thomas Gresik, 2013. "Allowing Firms to Choose Between Formula Apportionment and Separate Accounting Taxation," CESifo Working Paper Series 4560, CESifo Group Munich.

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