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Corporate tax regime and international allocation of ownership

  • Johannes Becker

    ()

    (Max PLanck Institute for Intellectual Property Munich)

  • Marco Runkel

    ()

    (Faculty of Economics and Management, Otto-von-Guericke University Magdeburg)

Would the introduction of a corporate tax system with consolidated tax base and formula apportionment lead to socially wasteful mergers and acquisitions across borders? This paper analyzes a two-country model with an international investor considering acquisitions of already existing target firms in a high-tax country and a low-tax country. The investor is able to shift profits from one location to another for tax saving purposes. Two systems of corporate taxation are compared, a system with separate accounting and a system with tax base consolidation and formula apportionment. It is shown that, under separate accounting, the number of acquisitions is inefficiently ciently high in both the high tax and the low tax country. Under formula apportionment, the number of acquisitions is inefficiently ciently high in the low tax country and inefficiently ciently low in the high tax country. Under tax competition, a novel externality arises that worsens the effciency; ciency properties of equilibrium tax rates under separate accounting, but may play an effciency; ciency enhancing role under formula apportionment.

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File URL: http://www.ww.uni-magdeburg.de/fwwdeka/femm/a2010_Dateien/2010_14.pdf
File Function: First version, 2010
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Paper provided by Otto-von-Guericke University Magdeburg, Faculty of Economics and Management in its series FEMM Working Papers with number 100014.

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Length: 17 pages
Date of creation: May 2010
Date of revision:
Handle: RePEc:mag:wpaper:100014
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  1. Jack Mintz & Michael Smart, 2001. "Income Shifting, Investment, and Tax Competition: Theory and Evidence from Provincial Taxation in Canada," CESifo Working Paper Series 554, CESifo Group Munich.
  2. Harry Huizinga & Luc Laeven, 2006. "International profit shifting within multinationals: a multi-country perspective," European Economy - Economic Papers 260, Directorate General Economic and Financial Affairs (DG ECFIN), European Commission.
  3. Haufler, Andreas & Schulte, Christian, 2011. "Merger policy and tax competition: The role of foreign firm ownership," Munich Reprints in Economics 20413, University of Munich, Department of Economics.
  4. 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.
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  7. Thiess Buettner & Nadine Riedel & Marco Runkel, 2008. "Strategic Consolidation under Formula Apportionment," Working Papers 0827, Oxford University Centre for Business Taxation.
  8. Thomas Eichner & Marco Runkel, 2008. "Corporate Income Taxation of Multinationals in a General Equilibrium Model," CESifo Working Paper Series 2320, CESifo Group Munich.
  9. Gordon, Roger H & Wilson, John Douglas, 1986. "An Examination of Multijurisdictional Corporate Income Taxation under Formula Apportionment," Econometrica, Econometric Society, vol. 54(6), pages 1357-73, November.
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  14. Jack M. Mintz, 1999. "Globalization of the Corporate Income Tax: The Role of Allocation," FinanzArchiv: Public Finance Analysis, Mohr Siebeck, Tübingen, vol. 56(3/4), pages 389-, July.
  15. Becker, Johannes & Fuest, Clemens, 2007. "Tax Enforcement and Tax Havens under Formula Apportionment," FiFo Discussion Papers - Finanzwissenschaftliche Diskussionsbeiträge 07-8, University of Cologne, FiFo Institute for Public Economics.
  16. Clemens Fuest & Thomas Hemmelgarn & Fred Ramb, 2007. "How would the introduction of an EU-wide formula apportionment affect the distribution and size of the corporate tax base? An analysis based on German multinationals," International Tax and Public Finance, Springer, vol. 14(5), pages 605-626, October.
  17. Wilson, John D., 1986. "A theory of interregional tax competition," Journal of Urban Economics, Elsevier, vol. 19(3), pages 296-315, May.
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  24. Kind, Hans Jarle & Midelfart, Karen Helene & Schjelderup, Guttorm, 2005. "Corporate tax systems, multinational enterprises, and economic integration," Journal of International Economics, Elsevier, vol. 65(2), pages 507-521, March.
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