IDEAS home Printed from https://ideas.repec.org/p/cpb/discus/450.html

Disentangling business- and tax-motivated bilateral royalty flows

Author

Listed:
  • Arjan Lejour

    (CPB Netherlands Bureau for Economic Policy Analysis)

  • Maarten van 't Riet

    (CPB Netherlands Bureau for Economic Policy Analysis)

Abstract

Multinational firms pay for the use of intellectual property (IP). The IP-rights may be located in another country where the royalty income is taxable. This taxation may differ between countries which offers opportunities for tax avoidance. This implies that bilateral royalty payments may not only be business motivated but may also be tax driven. We determine the shares of tax and business motivated flows. We estimate that at least 18% of the size of the flows is tax driven. The associated worldwide loss of tax revenue is between 6.5 and 16 billion US dollar.

Suggested Citation

  • Arjan Lejour & Maarten van 't Riet, 2023. "Disentangling business- and tax-motivated bilateral royalty flows," CPB Discussion Paper 450, CPB Netherlands Bureau for Economic Policy Analysis.
  • Handle: RePEc:cpb:discus:450
    DOI: 10.34932/0edy-v759
    as

    Download full text from publisher

    File URL: https://www.cpb.nl/system/files/cpbmedia/omnidownload/Discussion-Paper-450-Disentangling-business-and-tax-motivated-bilateral-royalty-flows.pdf
    Download Restriction: no

    File URL: https://libkey.io/10.34932/0edy-v759?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    Other versions of this item:

    References listed on IDEAS

    as
    1. Karkinsky, Tom & Riedel, Nadine, 2012. "Corporate taxation and the choice of patent location within multinational firms," Journal of International Economics, Elsevier, vol. 88(1), pages 176-185.
    2. Dischinger, Matthias & Riedel, Nadine, 2011. "Corporate taxes and the location of intangible assets within multinational firms," Journal of Public Economics, Elsevier, vol. 95(7), pages 691-707.
    3. Sunghoon Hong, 2018. "Tax treaties and foreign direct investment: a network approach," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(5), pages 1277-1320, October.
    4. Bucovetsky, S., 1991. "Asymmetric tax competition," Journal of Urban Economics, Elsevier, vol. 30(2), pages 167-181, September.
    5. Katarzyna Bilicka & Michael Devereux & Irem Güçeri, 2023. "Tax-Avoidance Networks and the Push for a “Historic” Global Tax Reform," Tax Policy and the Economy, University of Chicago Press, vol. 37(1), pages 57-108.
    6. Fuest, Clemens & Spengel, Christoph & Finke, Katharina & Heckemeyer, Jost H. & Nusser, Hannah, 2013. "Profit shifting and 'aggressive' tax planning by multinational firms: Issues and options for reform," ZEW Discussion Papers 13-078, ZEW - Leibniz Centre for European Economic Research.
    7. Dudar, Olena & Spengel, Christoph & Voget, Johannes, 2015. "The impact of taxes on bilateral royalty flows," ZEW Discussion Papers 15-052, ZEW - Leibniz Centre for European Economic Research.
    8. Kanbur, Ravi & Keen, Michael, 1993. "Jeux Sans Frontieres: Tax Competition and Tax Coordination When Countries Differ in Size," American Economic Review, American Economic Association, vol. 83(4), pages 877-892, September.
    9. Michael Overesch & Georg Wamser, 2014. "Bilateral internal debt financing and tax planning of multinational firms," Review of Quantitative Finance and Accounting, Springer, vol. 42(2), pages 191-209, February.
    10. Damgaard, Jannick & Elkjaer, Thomas & Johannesen, Niels, 2024. "What is real and what is not in the global FDI network?," Journal of International Money and Finance, Elsevier, vol. 140(C).
    11. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
    12. Maddalena Conte & Pierre Cotterlaz & Thierry Mayer, 2022. "The CEPII Gravity Database," Working Papers 2022-05, CEPII research center.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Giulia Aliprandi & Thijs Busschots & Carlos Oliveira, 2023. "Mapping the global geography of shell companies," Post-Print hal-04563980, HAL.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Arjan Lejour & Maarten van ’t Riet, 2025. "Tax avoidance by redirecting royalty flows: estimating the global revenue loss," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 32(5), pages 1289-1334, October.
    2. Arjan Lejour & Jan Möhlmann & Maarten ’t Riet, 2022. "The immeasurable tax gains by Dutch shell companies," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 29(2), pages 316-357, April.
    3. Giuseppe Pulina & Skerdilajda Zanaj, 2022. "Tax competition and phantom FDI," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 24(6), pages 1342-1363, December.
    4. Arjan Lejour & Jan Möhlmann & Maarten van 't Riet & Thijs Benschop, 2019. "Dutch Shell Companies and International Tax Planning," CPB Discussion Paper 402, CPB Netherlands Bureau for Economic Policy Analysis.
    5. Annette Alstadsæter & Julie Brun Bjørkheim & Ronald B. Davies & Johannes Scheuerer, 2022. "Pennies from Haven: Wages and Profit Shifting," Working Papers 002, EU Tax Observatory.
    6. S. Juranek & D. Schindler & A. Schneider, 2023. "Royalty taxation under tax competition and profit shifting," Canadian Journal of Economics/Revue canadienne d'économique, John Wiley & Sons, vol. 56(4), pages 1377-1412, November.
    7. Pfeiffer, Olena & Spengel, Christoph, 2017. "Tax incentives for research and development and their use in tax planning," ZEW Discussion Papers 17-046, ZEW - Leibniz Centre for European Economic Research.
    8. Kevin Parra Ramirez & Vincent Vicard, 2025. "The Instruments of Profit Shifting," Sciences Po Economics Discussion Papers hal-05496025, HAL.
    9. Baptiste Souillard, 2020. "Import Competition And Corporate Tax Avoidance: Evidence From The China Shock," Working Papers ECARES 2020-30, ULB -- Universite Libre de Bruxelles.
    10. Keuschnigg, Christian & Loretz, Simon & Winner, Hannes, 2014. "Tax Competition and Tax Coordination in the European Union: A Survey," Economics Working Paper Series 1427, University of St. Gallen, School of Economics and Political Science.
    11. Florence Lachet-Touya, 2016. "EU tax competition and tax avoidance: A multiprincipal perspective," Working papers of CATT hal-02939340, HAL.
    12. Garcia-Bernardo, Javier & Janský, Petr, 2024. "Profit shifting of multinational corporations worldwide," World Development, Elsevier, vol. 177(C).
    13. Gerda Dewit & Dermot Leahy, 2020. "Thinking inside the box: Optimal policy towards a footloose R&D‐intensive firm," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 22(6), pages 1921-1942, December.
    14. Gurshev, Oleg, 2025. "From Russia with love: Empirical evidence on affiliate profitability under sanctions and capital flight across borders," Economic Systems, Elsevier, vol. 49(3).
    15. Florence Lachet-Touya, 2016. "Horizontal and Vertical Tax Interactions in a Common Agency Game," Working papers of CATT hal-02939399, HAL.
    16. Sandro Montresor & Francesco Quatraro, 2015. "Key Enabling Technologies and Smart Specialization Strategies. European Regional Evidence from patent data," JRC Working Papers on Corporate R&D and Innovation 2015-05, Joint Research Centre.
    17. Wolfram F. Richter, 2017. "Taxing Intellectual Property in the Global Economy: A Plea for Regulated and Internationally Coordinated Profit Splitting," CESifo Working Paper Series 6564, CESifo.
    18. Joana Garcia, 2022. "Multinationals and services imports from havens: when policies stand in the way of tax planning," Working Papers w202214, Banco de Portugal, Economics and Research Department.
    19. Michael Overesch & Sina Willkomm, 2025. "The relation between corporate social responsibility and profit shifting of multinational enterprises," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 32(2), pages 466-500, April.
    20. Florence Lachet-Touya, 2016. "EU tax competition and tax avoidance: A multiprincipal perspective," Working Papers hal-02939340, HAL.

    More about this item

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm

    NEP fields

    This paper has been announced in the following NEP Reports:

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:cpb:discus:450. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: the person in charge (email available below). General contact details of provider: https://edirc.repec.org/data/cpbgvnl.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.