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Formula Apportionment: Factor Allocation and Tax Avoidance

Author

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  • Sebastian Eichfelder
  • Frank Hechtner
  • Jochen Hundsdoerfer

Abstract

This paper addresses the question of how firms react to tax incentives in a formula apportionment (FA) tax regime. Under FA, the profits of all consolidated entities of a business group are summed and then allocated according to a formula based on FA factors. We hypothesize that firms may change the allocation of real production factors and/or manipulate the FA factor through tax avoidance strategies. Analyzing FA tax effects of the German local business tax with payroll expense as the exclusive FA factor, we find empirical evidence consistent with both hypotheses. Regarding the allocation of production factors, we observe significant tax effects on labor input at the intensive margin but not on labor input at the extensive margin. In addition, we find evidence of an indirect FA spillover effect on capital investment. Our findings on tax avoidance proxies are consistent with tax-induced manipulations of payroll expense as an FA factor to save tax payments.

Suggested Citation

  • Sebastian Eichfelder & Frank Hechtner & Jochen Hundsdoerfer, 2018. "Formula Apportionment: Factor Allocation and Tax Avoidance," European Accounting Review, Taylor & Francis Journals, vol. 27(4), pages 649-681, August.
    • Handle: RePEc:taf:euract:v:27:y:2018:i:4:p:649-681
    DOI: 10.1080/09638180.2017.1364165
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    Cited by:

    1. Regina Ortmann & Erich Pummerer, 2023. "Distortional effects of separate accounting and formula apportionment on factor allocation," Journal of Business Economics, Springer, vol. 93(8), pages 1277-1307, October.
    2. Eichfelder, Sebastian & Jacob, Martin & Schneider, Kerstin, 2020. "Do tax incentives reduce investment quality?," arqus Discussion Papers in Quantitative Tax Research 248, arqus - Arbeitskreis Quantitative Steuerlehre.
    3. Eichfelder, Sebastian & Jacob, Martin & Schneider, Kerstin, 2023. "Do tax incentives affect investment quality?," Journal of Corporate Finance, Elsevier, vol. 80(C).
    4. Joana Andrade Vicente, 2023. "Rethinking corporate taxation in the European Union: how and where to tax Multinational Enterprises," Working Papers REM 2023/0286, ISEG - Lisbon School of Economics and Management, REM, Universidade de Lisboa.
    5. Schulte Sasse, Katharina & Watrin, Christoph & Weiß, Falko, 2020. "The alignment between reported profits and real activity in times of the BEPS Action Plan," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 40(C).
    6. Jochen Hundsdoerfer & Julia Wagner, 2020. "How accurately does the CCCTB apportionment formula allocate profits? An evaluation of the European Commission proposal," Journal of Business Economics, Springer, vol. 90(4), pages 495-536, May.

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