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Formula apportionment: Factor allocation and tax avoidance

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  • Eichfelder, Sebastian
  • Hechtner, Frank
  • Hundsdoerfer, Jochen

Abstract

This paper addresses the question of how firms react to tax incentives in a formula apportionment (FA) tax regime. Under FA, the profits of all consolidated entities of a business group are summed and then allocated according to a formula based on FA factors. We hypothesize that firms may change the allocation of real production factors and/or manipulate the FA factor through tax avoidance strategies. Analysing FA tax effects of the German local business tax with payroll expense as the exclusive FA factor, we find empirical evidence consistent with both hypotheses. Regarding the allocation of production factors, we observe significant tax effects on labour input at the intensive margin but not on labour input at the extensive margin. In addition, we find evidence of an indirect FA spillover effect on capital investment. Our findings on tax avoidance proxies are consistent with tax-induced manipulations of payroll expense as an FA factor to save tax payments.

Suggested Citation

  • Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2017. "Formula apportionment: Factor allocation and tax avoidance," arqus Discussion Papers in Quantitative Tax Research 220, arqus - Arbeitskreis Quantitative Steuerlehre, revised 2017.
    • Handle: RePEc:zbw:arqudp:220
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    References listed on IDEAS

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    More about this item

    Keywords

    Factor Allocation; Formula Apportionment; Profit Shifting; Tax Avoidance;
    All these keywords.

    JEL classification:

    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
    • H71 - Public Economics - - State and Local Government; Intergovernmental Relations - - - State and Local Taxation, Subsidies, and Revenue
    • H73 - Public Economics - - State and Local Government; Intergovernmental Relations - - - Interjurisdictional Differentials and Their Effects
    • J61 - Labor and Demographic Economics - - Mobility, Unemployment, Vacancies, and Immigrant Workers - - - Geographic Labor Mobility; Immigrant Workers

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