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The Taxation of Foreign Profits: a Unified View

Author

Listed:
  • Michael Devereux

    () (Oxford University Centre for Business Taxation)

  • Clemens Fuest

    () (Centre for European Economic Research (ZEW))

  • Ben Lockwood

    () (Oxford University CBT, CEPR and Department of Economics, University of Warwick,)

Abstract

This paper synthesizes and extends the literature on the taxation of foreign source income in a framework that covers both greenfield and acquisition investment, and a general constraint linking investment at home and abroad for the multinational by introducing a cost of adjustment for the mobile factor. Unless the cost of adjustment is zero, the domestic tax on foreign-source income should always be set to ensure the optimal allocation of the mobile factor between domestic and foreign assets and should follow the classical rules in the literature; national optimality requires the deduction rule, and global optimality requires the credit rule. Only in the zero-cost case does exemption become optimal. Allowances can be set so as to ensure that domestic and foreign asset purchases are undistorted by the tax system: this requires a cash-flow tax on domestic investment in the greenfield case, and a cross-border cash flow tax on foreign investment in both cases. These basic results extend to various extensions of the model.

Suggested Citation

  • Michael Devereux & Clemens Fuest & Ben Lockwood, 2013. "The Taxation of Foreign Profits: a Unified View," Working Papers 1303, Oxford University Centre for Business Taxation.
  • Handle: RePEc:btx:wpaper:1303
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    References listed on IDEAS

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    Cited by:

    1. Devereux, Michael P. & Fuest, Clemens & Lockwood, Ben, 2015. "The taxation of foreign profits: A unified view," Journal of Public Economics, Elsevier, vol. 125(C), pages 83-97.
    2. Peter Egger & Michael Stimmelmayr, 2017. "Taxation and the Multinational Firm," CESifo Working Paper Series 6384, CESifo Group Munich.
    3. von Hagen, Dominik & Pönnighaus, Fabian Nicolas, 2017. "International taxation and M&A prices," ZEW Discussion Papers 17-040, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
    4. Zadia M. Feliciano & Andrew Green, 2017. "US Multinationals in Puerto Rico and the Repeal of Section 936 Tax Exemption for U.S. Corporations," NBER Working Papers 23681, National Bureau of Economic Research, Inc.
    5. Margaret K. McKeehan & George R. Zodrow, 2017. "Balancing act: weighing the factors affecting the taxation of capital income in a small open economy," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 24(1), pages 1-35, February.
    6. David Weisbach, 2014. "The use of neutralities in international tax policy," Working Papers 1414, Oxford University Centre for Business Taxation.

    More about this item

    Keywords

    Corporate Taxation; Multinational Firms; Repatriation;

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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