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The Taxation of Foreign Profits: a Unified View

Listed author(s):
  • 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,)

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.

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File URL: http://www.sbs.ox.ac.uk/sites/default/files/Business_Taxation/Docs/WP1303.pdf
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Paper provided by Oxford University Centre for Business Taxation in its series Working Papers with number 1303.

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Date of creation: 2013
Handle: RePEc:btx:wpaper:1303
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  1. Johannes Becker, 2013. "Taxation of Foreign Profits with Heterogeneous Multinational Firms," The World Economy, Wiley Blackwell, vol. 36(1), pages 76-92, 01.
  2. Michael Devereux & Clemens Fuest & Ben Lockwood, 2013. "The Taxation of Foreign Profits: a Unified View," Working Papers 1303, Oxford University Centre for Business Taxation.
  3. Alan J. Auerbach & Michael P. Devereux, 2010. "Consumption and Cash-Flow Taxes in an International Setting," STICERD - Public Economics Programme Discussion Papers 03, Suntory and Toyota International Centres for Economics and Related Disciplines, LSE.
  4. Hamermesh, Daniel S. & Pfann, Gerard Antonie, 1996. "Adjustment Costs in Factor Demand," CEPR Discussion Papers 1371, C.E.P.R. Discussion Papers.
  5. Mihir C. Desai & C. Fritz Foley & James R. Hines Jr., 2005. "Foreign Direct Investment and the Domestic Capital Stock," NBER Working Papers 11075, National Bureau of Economic Research, Inc.
  6. Thomas Horst, 1980. "A Note on the Optimal Taxation of International Investment Income," The Quarterly Journal of Economics, Oxford University Press, vol. 94(4), pages 793-798.
  7. Devereux, Michael P & Hubbard, R Glenn, 2003. "Taxing Multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 10(4), pages 469-487, August.
  8. Swenson, Deborah L., 2001. "Tax Reforms and Evidence of Transfer Pricing," National Tax Journal, National Tax Association, vol. 54(n. 1), pages 7-26, March.
  9. Clausing, Kimberly A., 2003. "Tax-motivated transfer pricing and US intrafirm trade prices," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2207-2223, September.
  10. Roger H. Gordon & Hal R. Varian, 1986. "Taxation of Asset Income in the Presence of a World Securites Market," NBER Working Papers 1994, National Bureau of Economic Research, Inc.
  11. Joel Slemrod & Carl Hansen & Roger Procter, 1994. "The Seesaw Principle in International Tax Policy," NBER Working Papers 4867, National Bureau of Economic Research, Inc.
  12. Johannesen, Niels, 2010. "Imperfect tax competition for profits, asymmetric equilibrium and beneficial tax havens," Journal of International Economics, Elsevier, vol. 81(2), pages 253-264, July.
  13. Haufler, A. & Schjelderup, G., 1999. "Corporate Tax Systems and Cross Country Profit Shifting," Papers 1/99, Norwegian School of Economics and Business Administration-.
  14. Michael P. Devereux, 2004. "Some Optimal Tax Rules for International Portfolio and Direct Investment," FinanzArchiv: Public Finance Analysis, Mohr Siebeck, Tübingen, vol. 60(1), pages 1-1, April.
  15. Johannes Becker & Clemens Fuest, 2009. "Transfer Pricing Policy and the Intensity of Tax Rate Competition," Working Papers 0930, Oxford University Centre for Business Taxation.
  16. René BELDERBOS & FUKAO Kyoji & ITO Keiko & Wilko LETTERIE, 2010. "Global Fixed Capital Investment by Multinational Firms," Discussion papers 10044, Research Institute of Economy, Trade and Industry (RIETI).
  17. Kevin S Markle, 2012. "A Comparison of the Tax-motivated Income Shifting of Multinationals in Territorial and Worldwide Countries," Working Papers 1206, Oxford University Centre for Business Taxation.
  18. Sebastian Krautheim & Tim Schmidt-Eisenlohr, 2009. "Heterogeneous firms, "Profit Shifting" FDI and international tax competition," Post-Print halshs-00442818, HAL.
  19. PERALTA, Susana & WAUTHY, Xavier & VAN YPERSELE, Tanguy, "undated". "Should countries control international profit shifting?," CORE Discussion Papers RP 1795, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
  20. Haufler,Andreas, 2008. "Taxation in a Global Economy," Cambridge Books, Cambridge University Press, number 9780521047593, October.
  21. Desai, Mihir A. & Hines, James R. Jr., 2003. "Evaluating International Tax Reform," National Tax Journal, National Tax Association, vol. 56(3), pages 487-502, September.
  22. Laura Kawano & Joel Slemrod, 2012. "The Effect of Tax Rates and Tax Bases on Corporate Tax Revenues: Estimates with New Measures of the Corporate Tax Base," NBER Working Papers 18440, National Bureau of Economic Research, Inc.
  23. Huizinga, Harry & Laeven, Luc, 2008. "International profit shifting within multinationals: A multi-country perspective," Journal of Public Economics, Elsevier, vol. 92(5-6), pages 1164-1182, June.
  24. Johannes Becker & Clemens Fuest, 2010. "Taxing Foreign Profits With International Mergers And Acquisitions," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 51(1), pages 171-186, 02.
  25. Mihir A. Desai & C. Fritz Foley & James R. Hines Jr., 2005. "Foreign Direct Investment and Domestic Economic Activity," NBER Working Papers 11717, National Bureau of Economic Research, Inc.
  26. Becker, Johannes & Fuest, Clemens, 2011. "Source versus residence based taxation with international mergers and acquisitions," Journal of Public Economics, Elsevier, vol. 95(1), pages 28-40.
  27. Robert E. Lipsey & Guy V.G. Stevens, 1988. "Interactions between Domestic and Foreign Investment," NBER Working Papers 2714, National Bureau of Economic Research, Inc.
  28. Michael Keen & Hannu Piekkola, 1996. "Simple rules for the optimal taxation of international capital income," IFS Working Papers W96/18, Institute for Fiscal Studies.
  29. Pfann, Gerald A. & Verspagen, Bart, 1989. "The structure of adjustment costs for labour in the Dutch manufacturing sector," Economics Letters, Elsevier, vol. 29(4), pages 365-371.
  30. Grubert, Harry, 2005. "Comment on Desai and Hines, "Old Rules and New Realities: Corporate Tax Policy in a Global Setting"," National Tax Journal, National Tax Association, vol. 58(2), pages 263-274, June.
  31. Nuno Crespo & Maria Paula Fontoura, 2005. "Determinant Factors of FDI Spillovers – What Do We Really Know?," Working Papers Department of Economics 2005/06, ISEG - School of Economics and Management, Department of Economics, University of Lisbon.
  32. Herzer, Dierk & Schrooten, Mechthild, 2008. "Outward FDI and domestic investment in two industrialized countries," Economics Letters, Elsevier, vol. 99(1), pages 139-143, April.
  33. Hartman, David G., 1985. "Tax policy and foreign direct investment," Journal of Public Economics, Elsevier, vol. 26(1), pages 107-121, February.
  34. Desai, Mihir A. & Hines, James R. Jr., 2004. "Old Rules and New Realities: Corporate Tax Policy in a Global Setting," National Tax Journal, National Tax Association, vol. 57(4), pages 937-960, December.
  35. Shafik Hebous & Martin Ruf & Alfons Weichenrieder, 2010. "The Effects of Taxation on the Location Decision of Multinational Firms: M&A vs. Greenfield Investments," CESifo Working Paper Series 3076, CESifo Group Munich.
  36. Lorraine Eden & Luis F Juarez Valdez & Dan Li, 2005. "Talk softly but carry a big stick: transfer pricing penalties and the market valuation of Japanese multinationals in the United States," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 36(4), pages 398-414, July.
  37. Giorgia Maffini, 2012. "Territoriality, Worldwide Principle, and Competitiveness of Multinationals: A Firm-level Analysis of Tax Burdens," Working Papers 1210, Oxford University Centre for Business Taxation.
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