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Transfer Pricing Regulation and Taxation of Royalty Payments


  • Juranek, Steffen
  • Schindler, Dirk
  • Schjelderup, Guttorm


We analyze the implications of OECD methods to regulate transfer pricing and the role of a royalty tax for abusive transfer pricing. We show: (i) Under traditional methods, mispricing of royalty payments does not affect investment, but the Transactional Profit Split Method triggers higher investment to facilitate profit shifting. (ii) Royalty taxation reduces both profit shifting and investment. (iii) A royalty tax rate below the corporate tax rate leads to overinvestment in an ACE tax system.

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  • Juranek, Steffen & Schindler, Dirk & Schjelderup, Guttorm, 2017. "Transfer Pricing Regulation and Taxation of Royalty Payments," Annual Conference 2017 (Vienna): Alternative Structures for Money and Banking 168118, Verein für Socialpolitik / German Economic Association.
  • Handle: RePEc:zbw:vfsc17:168118

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    1. Haufler, Andreas & Schjelderup, Guttorm, 2000. "Corporate Tax Systems and Cross Country Profit Shifting," Oxford Economic Papers, Oxford University Press, vol. 52(2), pages 306-325, April.
    2. 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.
    3. Huizinga, Harry & Laeven, Luc & Nicodeme, Gaetan, 2008. "Capital structure and international debt shifting," Journal of Financial Economics, Elsevier, vol. 88(1), pages 80-118, April.
    4. Desai, Mihir A. & Foley, C. Fritz & Hines, James Jr., 2006. "Do tax havens divert economic activity?," Economics Letters, Elsevier, vol. 90(2), pages 219-224, February.
    5. Thomas Gresik & Petter Osmundsen, 2008. "Transfer pricing in vertically integrated industries," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 15(3), pages 231-255, June.
    6. Finke, Katharina & Fuest, Clemens & Nusser, Hannah & Spengel, Christoph, 2014. "Extending taxation of interest and royalty income at source: An option to limit base erosion and profit shifting?," ZEW Discussion Papers 14-073, ZEW - Leibniz Centre for European Economic Research.
    7. 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.
    8. Kant, Chander, 1988. "Endogenous transfer pricing and the effects of uncertain regulation," Journal of International Economics, Elsevier, vol. 24(1-2), pages 147-157, February.
    9. Hovakimian, Armen & Hovakimian, Gayane & Tehranian, Hassan, 2004. "Determinants of target capital structure: The case of dual debt and equity issues," Journal of Financial Economics, Elsevier, vol. 71(3), pages 517-540, March.
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    Cited by:

    1. Laszlo Goerke, 2019. "Corporate social responsibility and tax avoidance," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 21(2), pages 310-331, April.
    2. Koethenbuerger, Marko & Mardan, Mohammed & Stimmelmayr, Michael, 2019. "Profit shifting and investment effects: The implications of zero-taxable profits," Journal of Public Economics, Elsevier, vol. 173(C), pages 96-112.
    3. Bornemann, Tobias, 2018. "Do transfer pricing rules distort R&D investment decisions?," arqus Discussion Papers in Quantitative Tax Research 233, arqus - Arbeitskreis Quantitative Steuerlehre.
    4. repec:url:izvest:v:20:y:2019:i:1:p:13-24 is not listed on IDEAS
    5. Juranek, Steffen & Schindler, Dirk & Schneider, Andrea, 2018. "Royalty Taxation under Tax Competition and Profit Shifting," Annual Conference 2018 (Freiburg, Breisgau): Digital Economy 181568, Verein für Socialpolitik / German Economic Association.
    6. Kato, Hayato & Okoshi, Hiofumi, 2019. "Economic Integration and Agglomeration of Multinational Production with Transfer Pricing," Discussion Papers in Economics 62013, University of Munich, Department of Economics.

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    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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