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Exploring Residual Profit Allocation

Author

Listed:
  • Sebastian Beer
  • Ruud de Mooij
  • Shafik Hebous
  • Michael Keen
  • Li Liu

Abstract

Residual profit allocation (RPA) schemes have come to prominence in discussions of international tax reform but with almost nothing known about their economic impact. These schemes tax multinationals by allocating their "routine" profits to source countries and sharing their remaining "residual" profit across countries on some formulaic basis. This paper explores the implications, conceptual and empirical, of moving to some form of RPA. Residual profits are estimated to be substantial and concentrated in relatively few multinational enterprises. The impact on tax revenue appears beneficial for developing countries. Aggregate production efficiency is unlikely to increase unless routine profits are lightly taxed.

Suggested Citation

  • Sebastian Beer & Ruud de Mooij & Shafik Hebous & Michael Keen & Li Liu, 2023. "Exploring Residual Profit Allocation," American Economic Journal: Economic Policy, American Economic Association, vol. 15(1), pages 70-109, February.
    • Handle: RePEc:aea:aejpol:v:15:y:2023:i:1:p:70-109
    DOI: 10.1257/pol.20200212
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    Cited by:

    1. Hiroshi MUKUNOKI & Hirofumi OKOSHI & Dirk SCHINDLER, 2025. "Reallocating Taxing Rights and Online Trade: Pillar One as a partial formula apportionment," Discussion papers 25032, Research Institute of Economy, Trade and Industry (RIETI).
    2. Wolfram F. Richter, 2022. "Taxing Multinational Enterprises: A Theory-Based Approach to Reform," CESifo Working Paper Series 10119, CESifo.
    3. Kempkes, Gerhard & Stähler, Nikolai, 2021. "Re-allocating taxing rights and minimum tax rates in international profit taxation," Discussion Papers 03/2021, Deutsche Bundesbank.
    4. Cobham, Alex & Faccio, Tommaso & FitzGerald, Valpy, 2019. "Global inequalities in taxing rights: An early evaluation of the OECD tax reform proposals," SocArXiv j3p48, Center for Open Science.
    5. Garcia-Bernardo, Javier & Janský, Petr, 2024. "Profit shifting of multinational corporations worldwide," World Development, Elsevier, vol. 177(C).
    6. Klein, Daniel & Ludwig, Christopher A. & Nicolay, Katharina & Spengel, Christoph, 2021. "Quantifying the OECD BEPS indicators: An update to BEPS Action 11," ZEW Discussion Papers 21-013, ZEW - Leibniz Centre for European Economic Research.
    7. Wolfram F. Richter, 2025. "Correction: Residual profit splitting: a theory-based approach to tax multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 32(3), pages 918-918, June.
    8. Evgeniya Dubinina & Javier Garcia-Bernardo & Petr Janský, 2024. "The excess profits during COVID-19 and their tax revenue potential," Empirica, Springer;Austrian Institute for Economic Research;Austrian Economic Association, vol. 51(4), pages 1001-1036, November.
    9. Alou Adesse Dama & Gregoire Rota-Graziosi & Faycal Sawadogo, 2024. "The regressivity of CIT exemptions in Africa," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 31(3), pages 909-934, June.

    More about this item

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods
    • L25 - Industrial Organization - - Firm Objectives, Organization, and Behavior - - - Firm Performance

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