Transfer Pricing and Strategic Taxation of Globally Joint Inputs

This paper models strategic taxation policy of home and host governments when a multinational enterprise sets transfer prices on globally joint inputs such as research and development. Tax credit and deduction allowances, as well as no taxation of foreign-earned profits, result in identical optimal transfer-price solutions and national income effects in both countries. An equilibrium home-tax solution is to tax foreign-earned profits at a higher rate than domestically earned profits. The multiantional responds by shifting profits abroad through transfer-pricing mechanisms.     

The demand for tax haven operations

What types of firms establish tax haven operations, and what purposes do these operations serve? Analysis of affiliate-level data for American firms indicates that larger, more international firms, and those with extensive intrafirm trade and high R and D intensities, are the most likely to use tax havens. Tax haven operations facilitate tax avoidance both by permitting firms to allocate taxable income away from high-tax jurisdictions and by reducing the burden of home country taxation of foreign income. The evidence suggests that the primary use of affiliates in larger tax haven countries is to reallocate taxable income, whereas the primary use of affiliates in smaller tax haven countries is to facilitate deferral of U.S. taxation of foreign income. Firms with sizeable foreign operations benefit the most from using tax havens, an effect that can be evaluated by using foreign economic growth rates as instruments for firm-level growth of foreign investment outside of tax havens. One percent greater sales and investment growth in nearby non-haven countries is associated with a 1.5 to 2% greater likelihood of establishing a tax haven operation.     

The Inequality of Incomes in the UK: an essay in memory of Professor Sir Henry Phelps Brown

Using Henry Phelps Brown's distinction between discrimination before and within the labour market, this paper first reviews the inequality of achievements and incomes of an imaginary cohort of people passing through the life cycle of birth, infancy, schooling, further education and into the labour market. At each stage appropriate policies for reducing inequality by “levelling up"” are examined. Secondly, it summarises the unprecedented increase in income inequality in the 1980s and 1990s (after the period studied so extensively by Henry Phelps Brown) and discusses the role of a progressive taxation policy in the “leveling up” process.     

Federalism and horizontal equity across Switzerland and Germany: a new rationale for a decentralized fiscal structure

Higher wages in agglomerations often do not reflect an increase in purchasing power, because a high percentage of the wage increase has to be spend on housing. Thus, after housing is considered taxpayers may have identical disposable incomes, although gross as well as after-tax income may differ. This unequal treatment of taxpayers is due to the taxation of nominal incomes. If tax systems taxed income based on regionally adjusted purchasing power, horizontal equity would be assured. Since this is an unfeasible option, the differences could be corrected by allowing a deduction on housing costs. Given the large revenue losses, it seems unlikely that governments in OECD countries move to a system where rents are deductible in determining taxable income. Another alternative—taxation of potentially achievable income—is unfeasible due to political opposition. A final and less costly alternative is fiscal federalism. Granting autonomy to the lower levels of the government offers local governments the power to design the tax system in a way that reflects differences in living costs. Although this option does not necessarily imply that governments effectively design the tax schedule in that way, a comparison of Germany and Switzerland shows that governments are aware of these differences across regions. The paper concludes that granting tax autonomy to the lower tiers in Germany would make many citizens, especially in the Southern part, better off and would promote horizontal equity among German taxpayers.     

Redistribution with Unobservable Bequests: A Case for Taxing Capital Income

This paper addresses the question of the optimal taxation of labour and interest income in an overlapping generations model with two unobservable characteristics, ability and inheritance. We assume realistically that saving can only be taxed anonymously, whereas the tax on labour earnings can be individualized and made non-linear. In such a setting, we show that a withholding tax on interest income along with a non-linear tax on labour income is desirable. The role of interest income taxation is to indirectly tax inherited wealth.
JEL Classification D 63, H 2     

Jointly Optimal Taxes and Enforcement Policies in Response to Tax Evasion

Assuming the government cannot fully observe either individual types or incomes and jointly picks optimal taxes and audit policies against evasion can significantly alter standard results from optimal income taxation and tax‐evasion models, which treat these separately. We consider this when individuals differ in their risk preferences and incomes. Given the resulting complexity, supplementing analytic results with numerical analysis helps explain the structure of the resulting policies and how they change when the distribution of income or the revenue requirements of the government change. We do this analysis with and without audit errors and with incomes exogenous or affected by occupational choice.     

Time-consistent taxation in a dynastic family model with human and physical capital and a balanced government budget

Abstract .  This paper analyzes optimal, time consistent taxation in a dynastic family model with human and physical capital and with a balanced government budget. When tax revenue is used for publicly provided consumption or lump-sum transfers, leisure would be higher than its social optimum. Pareto optimal taxation requires taxing capital income more heavily than labour income and subsidizing investment at the same rate of the tax. Also, it requires either subsidizing labour at the same rate as a consumption tax or subsidizing consumption at the same rate as a labour income tax, and hence it is not a practical guide to policy. Further, a consumption tax, or equivalently a uniform income tax with investment subsidies at the same rate, can be improved on by taxing capital income more heavily than labour income.     

Nonlinear taxes in a life-cycle consistent model of family labour supply

This paper deals with family labour supply under nonlinear income taxation in a life-cycle consistent framework. A major purpose of the paper is, therefore, to bring together previous research on how to model joint supply decisions, life-cycle consistency and piecewise linear taxation, and then perform an econometric application using Swedish cross-section data. The paper starts by constructing an intertemporal model of household behaviour, which is used to derive optimal hours of work for the husband and the wife, respectively. Then, given the appropriate theoretical framework, the model is specified in a way suitable for econometric analysis. Regarding the estimation results, we find that both male and female labour supply are sensitive not only to changes in the own marginal wage rate and the virtual nonlabour income, but also to changes in the marginal wage rate of the spouse. The latter means that cross-wage effects are important when it comes to interpret the consequences of income taxation.     

Workforce or workfare? The optimal use of work requirements when labour is supplied along the extensive margin

This paper explores the use of workfare as part of a tax mix when labour supply responses are along the extensive margin. In an economy where the government has a priori chosen any tax‐and‐benefit schedule, we show that, despite their common goal of providing additional incentives for individuals to enter the labour force, workfare and an earned income tax credit are at odds with each other. We also show that, in the presence of an optimal nonlinear income tax, introducing unproductive workfare is always suboptimal when individuals face the same disutility of being on workfare. When this disutility is heterogeneous, unproductive workfare may be a useful policy tool.     

Income Shifting within a Dual Income Tax System: Evidence from the Finnish Tax Reform of 1993*

Dual income tax systems can suffer from income that shifts from progressively taxed labour income to capital income, which is taxed at a lower, flat rate. This paper empirically examines the 1993 Finnish dual income tax reform, which radically reduced the marginal tax rates on capital income for some, but not all, taxpayers. We measure how overall taxable income and the relative shares of capital income and labour income reacted to the reform. We find that the reform led to a small positive impact on overall taxable income, but part of the positive response was probably offset by income shifting among the self‐employed.     

Foreign direct investment under oligopoly: Profit shifting or profit capturing?

In this paper a model of taxation of foreign source corporate income is developed when the output market is not perfectly competitive. Profit shifting policies, similar to those in the new trade literature, are also present in the case of foreign direct investment (FDI). There are, however, important differences to the new trade theory since in case of FDI, (i) corporate taxation and double taxation relief are the policy instruments rather than output or revenue taxes, (ii) countries are not symmetric in the sense that the host country has the first right to tax the multinational's profit and the home country reacts by providing double taxation relief, and (iii) output but not corporate taxation is specific to imperfectly competitive industries. It is argued that (a) variants of a tax credit are analogous to export subsidies, (b) when the home country operates a tax credit system the host country's incentive to capture the multinational's profit is bounded under imperfect competition, (c) when the host country offers a tax holiday the home country should imitate this policy, and (d) in the presence of perfect competitive industries, double taxation relief is a good instrument to target imperfectly competitive industries.     

Constrained Pareto-optimal taxation of labour and capital incomes

With the Pareto principle as the sole normative criterion, necessary conditions for optimal tax rates on labour and capital incomes are established in an overlapping-generations model. The individuals in the economy have differing earning abilities and their labour supply is endogenous. The analysis focuses on intragenerational aspects and is restricted to linear taxation in steady state.     

Good Jobs,Bad Jobs and Redistribution*

We analyse the question of optimal taxation in a dual economy, when the policy‐maker is concerned about the distribution of labour income. Income inequality is caused by the presence of sunk capital investments, which creates a “good jobs” sector due to the capture of quasi‐rents by trade unions. With strong unions and high planner preference for income equality, the optimal policy is a combination of investment subsidies and progressive income taxation. If unions are weaker, the policy‐maker may instead choose to tax investment.     

Tax Riots

This paper considers an optimal taxation environment where household income is private information, and the government randomly audits and punishes households found to be underreporting. We prove that the optimal mechanism derived using standard mechanism design techniques has a bad equilibrium (a tax riot) where households underreport their incomes, precisely because other households are expected to do so as well. We then consider three alternative approaches to designing a tax scheme when one is worried about bad equilibria.     

Optimal nonlinear income taxation with learning-by-doing

This paper examines a two-period model of optimal nonlinear income taxation with learning-by-doing, in which second-period wages are an increasing function of first-period labour supply. We consider the cases when the government can and cannot commit to its second-period tax policy. In both cases, the canonical Mirrlees/Stiglitz results regarding optimal marginal tax rates generally no longer apply. In particular, if the government cannot commit and each consumer's skill-type is revealed, it is optimal to distort the high-skill type's labour supply downwards through a positive marginal tax rate to relax an incentive-compatibility constraint. Our analysis therefore identifies a setting in which a positive marginal tax rate on the highest-skill individual can be justified, despite its depressing effect on both labour supply and wages.     

中国资源税问题研究与改革取向

随着经济的不断发展,中国原有的资源税暴露出许多弊端,如资源税课税范围较窄、依据不合理、单位税额总体偏低、对级差收入调节不够等,中国资源税改革应在借鉴国外税制的基础上,扩大征税范围,提高税率和按量计征,强化资源节约和环境保护.     

Optimal Taxation with a Trade-off Between Income and Children

This paper explores the implications of endogenous fertility for optimal redistributive taxation in the presence of a trade-off between labour income and children. The labour supply is a decreasing function of the desired quantity and quality of children. Since children enter into the parent's budget constraint in a nonlinear form, their shadow prices are directly distorted by the income tax rate. It is shown that the substitution effects of the income tax rate on the quantity and quality of children cannot be signed uniquely although the effect on labour supply is negative. The aggregate substitution effect of the income tax rate on the quantity of children plays an important role in the determination of the signs of the income tax and child subsidy rates at a Rawlsian or Benthamite social welfare optimum.
JEL Classification Numbers: H21, J13, J22     

Optimal Redistributive Taxation in a Search Equilibrium Model

This paper characterizes optimal non-linear income taxation in an economy with a continuum of unobservable productivity levels and endogenous involuntary unemployment due to frictions in the labour markets. Redistributive taxation distorts labour demand and wages. Compared to their efficient values, gross wages, unemployment, and participation are lower. Average tax rates are increasing. Marginal tax rates are positive, even at the top. Finally, numerical simulations suggest that redistribution is much more important in our setting than in a comparable Mirrlees-type setting.     

Poverty and Political Risk

The paper explains the negative correlation between developing countries' per capita incomes and measures of political risk by relating a government's decision to tax foreign investors to distributional interests in the host country's population. Using a dynamic general-equilibrium model in which agents make irreversible investments abroad to insure against country-specific technology shocks, it is shown that the political risk for foreign investors is prohibitive if the host country's initial per capita income is too low and if the benefits of international diversification are not high enough to generate a sufficiently strong opposition against discriminatory taxation.