Capital income taxation,tax criteria,and intergenerational welfare

In a two-period overlapping-generations model, residence criteria are shown to be optimal with lump-sum transfers to the younger generation in a dynamically efficient open economy even if all wage income, corresponding to rent income under exogenous labor supply, is not taxed away. When tax revenues are also distributed to the older generation — which indeed may be desirable for short-term intergenerational welfare distribution reasons — a weighted average rule is derived for optimal international taxation. The taxation of domestic savings income follows the inverse elasticity rule in respect to savings and, surprisingly, higher investment elasticity increases the tax level. Finally, for a small open economy and for large identical economies, tax competition with a mixed scheme of residence-based taxes and source-based subsidies yields the same tax policy as tax cooperation with no restrictions on the domestic and international capital income tax instruments.     

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.     

Regional Integration and the Co-ordination of Capital Income Taxation

This paper addresses the question of the need for income tax harmonization in the context of regional integration. It analyses the international distortions and fiscal interdependence arising in the presence of tax rate differentials both under a theoretical and an empirical perspective, and with reference to actual experiences of harmonization attempts. Attention is also paid to the influence of the countries' size on the results, to the strategic behaviour of countries under different international taxations rules, and to the relationships with the countries excluded by the integration process. International tax uniformity does not appear to be the preferable solution, even if some form of concerted agreements might help in reducing inefficiencies deriving from taxation differentials. For instance, in the case of highly mobile factors, like financial capital, if the integrating countries apply the source principle and the interest rate is the same across them, the source-based tax rate on non residents must equal the residence country tax rate on residents. Such a rule would allow the countries to set autonomously their tax rate and, at the same time, eliminate cross-border effects. If there are more than two integrating countries, the tax rates on non residents should discriminate according to the internal tax rate of the residence country.
(J.E.L.: H87, F20, H20).     

TAXING FOREIGN PROFITS WITH INTERNATIONAL MERGERS AND ACQUISITIONS*

A large part of border crossing investment takes the form of international mergers and acquisitions. In this article, we ask how optimal repatriation tax systems look like in a world where investment involves a change of ownership, instead of a reallocation of real capital. We find that the standard results of international taxation do not carry over to the case of international mergers and acquisitions. The deduction system is no longer optimal from a national perspective and the foreign tax credit system fails to ensure global optimality. The tax exemption system is optimal if ownership advantage is a public good within the multinational firm. However, the cross‐border cash‐flow tax system dominates the exemption system in terms of optimality properties.     

Renegotiation–Proof Equilibria in a Global Emission Game When Players Are Impatient

In a two-country model, in which countries differ with respect to the perception of environmental damages and abatement costs, the stability of international environmental agreements is analyzed in a dynamic framework. Three types of agreements are considered: A socially optimal solution, a uniform emission tax (a tax equally applied in both countries) and a uniform emission reduction quota (an equal percentage emission reduction from a base year). Stability is checked for these agreements according to the concept of renegotiation-proofness. It is shown that the stability requirements depend crucially on the parameters defining the interests of the two countries and the type of agreement. Moreover, it is demonstrated that if punishment options are restricted for some reason the stability of an agreement may suffer. One important result of the paper is that if countries exhibit asymmetric interests, stability in the quota regime is higher than in the tax regime and in the social optimum. This might explain why emission reduction quotas have been so popular in international politics despite recommendations of economists to use market-based instruments.     

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.     

Tax Evasion,Corruption and Market Entry

We analyze the impact of tax policy on the market entry of firms in the presence of corruption and tax evasion. In a world with corruption, firms must bribe corrupt officials to enter the market. For a given level of bribes, higher tax rates and stricter enforcement of taxation decrease tax evasion but typically reduce market entry. However, when the level of bribes reacts to tax policy, higher taxes and stricter enforcement of taxation can have a double benefit. Up to a certain threshold, for which we develop a simple rule, stricter enforcement increases market entry and reduces tax evasion.     

Coalition Stability in Public Goods Provision: Testing an Optimal Allocation Rule

We test the canonical model of international environmental agreements (IEAs) in a laboratory setting with asymmetric agents. IEA participation represents coalition formation and public good provision where there are gains to cooperation, but an incentive to free-ride. We test four competing methods of dividing the coalition’s worth: a recently proposed optimal rule which accounts for subjects’ payoffs as a single free-rider, the Shapley value, the Nash bargaining solution, and an equal split. Each treatment generates the theoretically predicted coalition size more often than not. The shares of the potential gains to cooperation achieved by each rule are: 51, 36, 40 and 13%, respectively. These results highlight the importance of using an optimal rule to improve IEAs, and more broadly for voluntary public good provision.     

Corporate tax rates and foreign direct investment in the United States

A significant research effort has been directed at establishing the determinants of foreign direct investment (FDI), with taxation policy identified as an important factor. However, the empirical literature has been limited in several respects, with most work focused exclusively on host country tax regimes. This paper seeks to extend the boundaries of FDI empirical inquiry by using a panel of nine investing tax exemption and tax credit countries over the period 1982–2000, constituting more than 85% of total US FDI inflows, and incorporating home country tax rates to analyse two as yet unanswered questions. First, are corporate income tax rates an important determinant of FDI in the US? Secondly, do investors from tax credit countries differ significantly in their tax response relative to those from tax exemption countries?     

Income Taxation Rules and Stability of a Small Open Economy

This paper examines the stability of a small open economy under alternative income taxation rules. Using a one-sector real business cycle model with external increasing returns, we show that if the income tax schedule is linear, the small open economy will not generate equilibrium indeterminacy, but it exhibits a diverging behavior under certain conditions. In this case, an appropriate choice of nonlinear tax on the factor income may recover the saddle-point stability. We also reveal that if the taxation on the interest income on financial assets is regressive, then the small open economy may exhibit equilibrium indeterminacy. In this situation, a progressive tax rule on the interest income can contribute to eliminating sunspot-driven fluctuations.     

Altruism and the Political Economy of Income Taxation

I develop a model in which altruistic agents vote over quadratic income tax schedules. Agents have heterogeneous preferences and productivities, and the model incorporates the incentive effects of taxation. The main result of the paper establishes the existence of a self-confirming majority rule equilibrium in which agents' labor supply decisions are optimal given their tax liabilities and the tax policy is a majority rule equilibrium given the labor supply decisions. In equilibrium the actions by all agents confirm their expectations, but such expectations may be incorrect out of equilibrium. The model generates majority rule voting equilibria that involve progressive taxation.     

欧洲主要发达国家近期税制改革及其对中国的启示

近两年,以英、德、法为首的欧洲主要发达国家针对经济和财政运行中出现的新问题,纷纷制定了符合本国国情的税制改革方案,希望通过调整税收制度来改善社会经济运行环境。中国制定新一轮税制改革方略应立足中国现实,而设计税制改革目标的方案需视国际税收的影响、坚持税收中性和政府调控相结合的原则,进一步完善税制结构。     

论诚信征税机制的构建——基于制度经济学的视角

税收作为社会经济活动的一项主要内容,当前面临着诚信问题,尤其是征税诚信已经成为构建税收诚信体系亟待解决的问题。因此,通过有效的制度安排,建立和完善诚信征税机制具有重要的现实意义。本文建议主要通过四个方面来实现诚信征税:一是加强税收制度建设,实施正式约束;二是优化税收征管体制,完善制度实施保障机制;三是建立税收诚信文化,实施非正式约束;四是建立激励惩罚机制,约束征税人微观行为。     

Optimality properties of alternative systems of taxation of foreign capital income

Foreign source capital income taxes are examined from the point of view of optimal taxation. In the framework of a simple economy with international real capital flows, a taxonomy of alternative systems of such taxation is first presented, showing how crediting and other tax parameters induce what are called source-based, residence-based and related systems. Next, tax rates are determined that are optimal from a single country's point of view, given those of the others. The achievability of these rates under the various systems is analyzed. Finally, tax rates that are optimal from an international point of view are considered. Again, achievability of an international optimum under the various systems is considered, leading to the main conclusions that (i) a pure residence-based system in all countries can achieve an international fiscal optimum; (ii) it cannot, however, be sustained as an equilibrium.     

A Public Choice Approach to Strategic and Nonstrategic Environmental Policy

In this paper we take a public choice perspective on strategic environmental policy and international environmental agreements. We examine cooperative and noncooperative environmental policies under governments that are either welfare maximizers (“good dictators”) or tax revenue maximizers (“Leviathans”). We show that Leviathans can perform better in terms of welfare and that good dictators can set higher taxes. We then analyze international environmental agreements and show that the breakdown of environmental cooperation can indeed lead to a welfare gain for all signatory countries. Considering a delegation game between governments, we find that a Pareto‐superior Leviathan outcome can be the unique Nash equilibrium.     

The inflation tax in an open economy with imperfect competition

This paper studies the national welfare maximizing inflation tax in an open economy with imperfect competition. It shows that the presence of a monopolistic distortion dampens the incentive to engage in strategic use of the inflation tax. If this dampening effect is strong enough, monetary policy becomes completely inward-looking, restoring the Friedman rule as an equilibrium strategy regardless of the actions of the foreign government. This aspect of the policy interaction—driven entirely by the presence of imperfect competition—is important because it determines the underlying structure of the policy game and is therefore crucial for determining whether or not there exist welfare gains from international monetary cooperation.     

The role of infrastructure investment and factor productivity in international tax competition

In this paper we use data from 30 developed economies from 1999 to 2014 to analyse the importance of infrastructure investments and factor productivity for explaining international capital tax competition. Our results indicate the existence of intensive tax competition in effective average corporate taxation during this period. It is also suggested that non-tax variables of third countries affect a country's corporate tax policy. Countries whose direct competitors have better infrastructures or are more productive compensate with lower capital taxation. In this way, their infrastructure investment and productivity-enhancing policies are used as strategic substitutes for capital taxation. With regard to the characteristics of closest competitors, we find that corporate tax competition is fiercer among countries that are characterized by similar infrastructure investments and geographical proximity.     

网络背景下的税收管辖权问题研究

税收管辖权主要分为两种,一种是属人管辖权,另一种是属地管辖权。但是,不论是属人税收管辖权还是属地税收管辖权都是一种不完全的税收管辖权,都存在许多征税漏洞。对国际税收法律体制进行适合于电子商务的改造或者变革,不仅仅是一项法律制度通常的改变,而是具有划时代意义的举措,这表明从此以后我们不但要关注现实的世界,还要时时留意那个数字化空间的影响。从这一意义上说,电子商务税收法律制度必定是一个十分重大的命题。     

On the undesirability of commodity taxation even when income taxation is not optimal

An important result due to Atkinson and Stiglitz (1976) [Atkinson, A.B., Stiglitz, J.E., 1976. The design of tax structure: Direct versus indirect taxation. Journal of Public Economics 6, 55–75.] is that differential commodity taxation is not optimal in the presence of an optimal nonlinear income tax (given weak separability of utility between labor and all consumption goods). This article demonstrates that this conclusion holds regardless of whether the income tax is optimal. In particular, given any commodity tax and income tax system, differential commodity taxation can be eliminated in a manner that results in a Pareto improvement. Also, differential commodity taxation can be proportionally reduced so as to generate a Pareto improvement. In addition, for commodity tax reforms that neither eliminate nor proportionally reduce differential taxation, a simple efficiency condition is offered for determining whether a Pareto improvement is possible.     

经济全球化下的国际税收竞争与税收优惠

本文从经济全球化入手,论述了经济全球化、税收国际化、国际税收竞争与税收优惠的关系,主张纵向研究国际税收竞争,从国民经济发展的全局出发审视利用税收优惠手段参与国际税收竞争的利与弊.