| 来源类型 | Discussion paper |
| 规范类型 | 论文 |
| 来源ID | DP10512 |
| DP10512 The Taxation of Foreign Profits: a Unified View | |
| Michael Devereux; Ben Lockwood; Clemens Fuest | |
| 发表日期 | 2015-03-29 |
| 出版年 | 2015 |
| 语种 | 英语 |
| 摘要 | This paper synthesizes and extends the literature on the taxation of foreign source income in a framework that covers both greenfield and acquisition investment, and a general constraint linking investment at home and abroad for the multinational by introducing a cost of adjustment for the mobile factor. Unless the cost of adjustment is zero, the domestic tax on foreign-source income should always be set to ensure the optimal allocation of the mobile factor between domestic and foreign assets and should follow the classical rules in the literature; national optimality requires the deduction rule, and global optimality requires the credit rule. Only in the zero-cost case does exemption become optimal. Allowances can be set so as to ensure that domestic and foreign asset purchases are undistorted by the tax system: this requires a cash-flow tax on domestic investment in the greenfield case, and a cross-border cash flow tax on foreign investment in both cases. These basic results extend to various extensions of the model, notably (i) when a profit-shifting motive is present; (ii) to some extent, when a corporate income tax is in place. The introduction of tax administration costs into the model can explain the empirical trend towards use of the exemption regime. |
| 主题 | International Trade and Regional Economics ; Public Economics |
| 关键词 | Corporate taxation Multinational firms Repatriation |
| URL | https://cepr.org/publications/dp10512 |
| 来源智库 | Centre for Economic Policy Research (United Kingdom) |
| 资源类型 | 智库出版物 |
| 条目标识符 | http://119.78.100.153/handle/2XGU8XDN/539344 |
| 推荐引用方式 GB/T 7714 | Michael Devereux,Ben Lockwood,Clemens Fuest. DP10512 The Taxation of Foreign Profits: a Unified View. 2015. |
| 条目包含的文件 | 条目无相关文件。 | |||||
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