Puzzles Over International Taxation of Cross Border Flows of Capital Income
I discuss the tax treatment of transborder capital income, focussing on prevailing arrangements rather than de novo design of optimal tax arrangements. These comprise unilateral reliefs from double taxation under credit or exemption systems, and treaty reliefs (largely following the OECD model treaty) which jointly lower withholding tax rates on interest, dividends, and royalties in both host and source countries. I suggest that these arrangements involve both seemingly non-strategic unilateral actions and cooperative arrangements which are difficult to reconcile both with tax competition literature and with national interest. I pose four puzzles in this regard. The first is that from a national welfare point of view, the unilateral reliefs in use seem inferior to no relief since with competitive markets investors equate the private return on investments at home and abroad, while tax revenues largely accrue to the foreign government. Private returns are equated, but national returns are not. The second is that tax treaties only have lump sum effects between national governments if the more common credit arrangements of unilateral reliefs apply and if tax rates are similar in host and source countries (approximately the OECD situation). This raises the issue of why governments negotiate them. The third is the sharp contrast to international treaty arrangements for goods flows under the WTO; and the fourth is the absence of side payments in tax treaties. The picture emerging is that making sense of present arrangements from a national welfare point of view and in terms of efficient instrument design seems difficult. The gap relative to optimal tax considerations also seems large.
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- Assaf Razin & Joel Slemrod, 1990. "Taxation in the Global Economy," NBER Books, National Bureau of Economic Research, Inc, number razi90-1, April.
- Janeba, Eckhard, 1995.
"Corporate income tax competition, double taxation treaties, and foreign direct investment,"
Journal of Public Economics,
Elsevier, vol. 56(2), pages 311-325, February.
- Janeba,Eckhard, 1991. "Corporate income tax competition,Double taxation treaties, and foreign direct investment," Discussion Paper Serie A 361, University of Bonn, Germany.
- Janeba, Eckhard, 1992. "Corporate income tax competition, double taxation treaties, and foreign direct investment," Discussion Papers, Series II 194, University of Konstanz, Collaborative Research Centre (SFB) 178 "Internationalization of the Economy".
- Kalai, Ehud & Smorodinsky, Meir, 1975. "Other Solutions to Nash's Bargaining Problem," Econometrica, Econometric Society, vol. 43(3), pages 513-518, May.
- Markusen, James R., 1983. "Factor movements and commodity trade as complements," Journal of International Economics, Elsevier, vol. 14(3-4), pages 341-356, May.
- Nash, John, 1950. "The Bargaining Problem," Econometrica, Econometric Society, vol. 18(2), pages 155-162, April.
- Wilson, John Douglas, 1999. "Theories of Tax Competition," National Tax Journal, National Tax Association, vol. 52(2), pages 269-304, June.
- Bond, Eric W & Samuelson, Larry, 1989. "Strategic Behaviour and the Rules for International Taxation of Capital," Economic Journal, Royal Economic Society, vol. 99(398), pages 1099-1111, December.
- Bond, E.W. & Samuelson, L., 1988. "Strategic Behavior And The Rules For International Taxation Of Capital," Papers 3-88-10, Pennsylvania State - Department of Economics.
- Gordon, Roger H, 1986. "Taxation of Investment and Savings in a World Economy," American Economic Review, American Economic Association, vol. 76(5), pages 1086-1102, December.
- Bruce, N., 1992. "Why Are There Foreign Tax Credits," Working Papers 92-08, University of Washington, Department of Economics.
- Bruce, N., 1992. "Why Are There Foreign Tax Credits," Discussion Papers in Economics at the University of Washington 92-08, Department of Economics at the University of Washington.
- Hines, James Jr., 1994. "Credit and deferral as international investment incentives," Journal of Public Economics, Elsevier, vol. 55(2), pages 323-347, October.
- James R. Hines Jr., 1992. "Credit and Deferral as International Investment Incentives," NBER Working Papers 4191, National Bureau of Economic Research, Inc.
- Hugh J. Ault & David F. Bradford, 1990. "Taxing International Income: An Analysis of the U.S. System and Its Economic Premises," NBER Chapters, in: Taxation in the Global Economy, pages 11-52 National Bureau of Economic Research, Inc.
- David F. Bradford & Hugh J. Ault, 1989. "Taxing International Income: An Analysis of the U.S. System and Its Economic Premises," NBER Working Papers 3056, National Bureau of Economic Research, Inc.
- Philippe Bacchetta & María Espinosa, 2000. "Exchange-of-Information Clauses in International Tax Treaties," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 7(3), pages 275-293, May.
- Hartman, David G., 1985. "Tax policy and foreign direct investment," Journal of Public Economics, Elsevier, vol. 26(1), pages 107-121, February.
- Wilson, John Douglas, 1999. "Theories of Tax Competition," National Tax Journal, National Tax Association, vol. 52(n. 2), pages 269-304, June. Full references (including those not matched with items on IDEAS)