Why the European Union Should Adopt Formula Apportionment with a Sales Factor*

Using a two‐country tax competition model with a multinational enterprise (MNE), this paper addresses the question of whether the European Union should replace separate accounting (SA) in corporate income taxation by formula apportionment (FA) and, if so, which apportionment factors should be used. Our main result is that FA with a sales factor may mitigate or even eliminate fiscal externalities caused by the countries' tax policy. Hence, our analysis provides a microfoundation for the sales apportionment factor. In an empirical calibration to the EU‐15 we show that the transition from SA to FA with a sales‐only formula raises average tax rates by 2% and average tax revenues by 1 billion euros or 0.1% of GDP. These effects result in an increase of welfare.     

Formula apportionment vs. separate accounting: A private information perspective

In 2002, the European Commission recommended that member countries use formula apportionment procedures to tax multinational companies. This departure from the standard separate accounting (transfer pricing) approach is an attempt to reduce the costs and distortions associated with auditing transfer prices. Unfortunately, apportionment formulas create their own economic distortions and, contrary to popular belief, they do not eliminate distortions due to asymmetric information between the multinational and the national tax authorities. In this paper, I explicitly model the role of private information in two tax competition games: one in which tax liabilities are calculated under formula apportionment and one in which tax liabilities are calculated under separate accounting and transfer prices are audited. Switching to a formula apportionment system affects the after-tax profit of multinationals and the tax revenues paid by both domestic and foreign firms. The direction and magnitude of the changes depend on the accuracy of the auditing technology and non-monotonically on multinational costs. The switch will have different effects on the tax receipts from domestic and foreign firms.     

Symmetric Tax Competition under Formula Apportionment

This paper compares property taxation to a corporate income tax based on formula apportionment in a model where identical countries compete to attract capital. We find that if countries can pair a residence–based capital tax with a property tax (source tax on capital) the tax equilibrium is efficient. In contrast, the use of a 2–factor FA scheme based on sales and capital combined with a residence–based capital tax leads to an inefficient outcome.     

How much profit shifting do European banks do?

This paper studies whether and to what extent the largest and systemically relevant European multinational banks engage in profit shifting to lower their tax burden. We exploit unique data on bank operations reported on a country-by-country basis since 2015 in compliance with European legislation. The dataset contains information on profits, turnover, taxes paid and employment of bank affiliates worldwide, including tax and regulatory havens. In our empirical model, profits shifting incentives are captured through a weighted average of international tax rate differences between all countries where the bank is active. We find that international tax differences trigger the geographical distribution of profits within multinational banks, and that low tax jurisdictions, notably tax havens, attract disproportionately high profits. Our results suggest that, overall, 21% of profits is shifted. Moreover, profits in tax havens are 51% higher than they would be without tax-motivated profit shifting, pointing to a significant reduction of tax bases in high-tax countries.     

Company taxation and tax spillovers: Separate accounting versus formula apportionment

It is observed in the real world that taxes matter for location decisions and that multinationals shift profits by transfer pricing. The US and Canada use so-called formula apportionment (FA) to tax corporate income, and the EU is debating a switch from separate accounting (SA) to FA. This paper develops a theoretical model that compares basic properties of FA to SA. The focal point of the analysis is how changes in tax rates affect capital formation, input choice, and transfer pricing, as well as on spillovers on tax revenue in other countries. The analysis shows that a move from SA to FA will not eliminate such spillovers and will, in cases identified in the paper, actually aggravate them.     

Index to Volume 52, 2000

In an efficiency wage economy with variable profits, a shift from payroll to employment taxes will reduce unemployment if the tax level is held constant at the initial wage. However, unemployment will rise if firms are constrained to zero profits in the long run and if tax revenues are constant. This reversal of employment effects occurs because the shift in taxes reduces wages. This implies a budget deficit. Hence, taxes will have to be raised if revenues are held constant. If the firm's profits cannot change, the tax increase will cause some firms to close down and unemployment will rise. Thus, the predicted employment consequences of changes in the tax structure depend on assumptions about the time horizon and budget constraint.     

控制权性质影响税收敏感性吗?——基于企业劳动力需求的检验

西方学者研究表明企业所得税是劳动力需求的重要影响因素,这一理论在中国是否适用?中国大部分上市公司为国有控股企业,这一特殊的制度背景是否会影响企业所得税与劳动力需求的关系?本文基于2007年企业所得税改革这一外生政策变化,在检验西方企业所得税与劳动力需求关系的理论在中国是否适用的基础上,就不同控制权的性质是否会影响企业劳动力需求的税收敏感性进行了检验。研究发现企业所得税税率降低和"就业税盾"增加提高了企业劳动力需求,但这种税率和"就业税盾"的变化对国有控股企业劳动力需求变化的影响要显著小于非国有控股企业。这表明税收是影响企业劳动力需求的重要因素,但国有控制权使得这种税收敏感性变弱。本文的研究结果不仅丰富了相关领域的国际学术文献,而且对我国就业政策的制定具有政策含义。     

THE CHOICE OF APPORTIONMENT FACTORS UNDER FORMULA APPORTIONMENT*

This paper investigates the choice of apportionment factors under a corporate tax system of Formula Apportionment. In contrast to perceived wisdom, we show that the apportionment formula contains both mobile (capital) and immobile (labor) factors, regardless of whether the formula is determined decentrally by jurisdictions or centrally by a central planner. The central planner uses the formula as a corrective instrument to internalize fiscal externalities. We calibrate the model to the European Union and show that replacing the current system of Separate Accounting by Formula Apportionment would substantially increase tax revenue and welfare under both centralized and decentralized formula choices.     

Equalizing tax bases or tax revenues under tax competition? The role of formula apportionment

This paper contributes to the literature on fiscal equalization and corporate tax competition. The innovation is that we explicitly model multinational enterprises and a corporate tax system that is designed according to formula apportionment. Two main results are obtained. First, in contrast to previous studies we identify cases where tax revenue equalization is better in mitigating detrimental tax competition than tax base equalization. Second, tax base equalization nevertheless has the advantage that it may render tax rates efficient, depending on the shape of the apportionment formula. A pure payroll formula does not ensure efficiency, but a back‐of‐the‐envelope calibration of our model to Canadian provinces suggests that a pure sales formula may be optimal.     

中国矿业税费法律制度的重构——以矿产所有权出让为视角

从实证分析的角度而言,在采矿权出让中,国家出让的是矿产的所有权而非用益物权。采矿权价款作为矿产的用益物权的对价,占矿产品的实际销售收入的比例太低。按矿产品的实际销售收入征收矿产资源补偿费和税收,国有矿产资源资产和税收大量流失。我国应实行矿产所有权出让,向受让人收取矿产所有权出让金、矿区国有土地使用费、矿山环境恢复费。根据矿产所有权出让金的数学模型,确定它的合理金额。按照同矿产的可采储量等量的矿产品的销售收入,征收环境税、增殖税,取消矿产资源补偿费和资源税。     

Corporate taxation, debt financing and foreign-plant ownership

This paper compares domestically and foreign-owned plants with respect to their debt-to-assets ratio and analyzes to which extent the difference is systematically affected by corporate taxation. To derive hypotheses about influence of corporate taxation on a firm's debt financing we adapt a standard model of taxation and financing decisions of firms for the case of international debt shifting activities of foreign-owned firms. We estimate the average difference between a foreign-owned and a domestically owned firm's debt ratio, treating the mode of ownership as endogenous. Using data from 32,067 European firms, we find that foreign-owned firms on average exhibit a significantly higher debt ratio than their domestically owned counterparts in the host country. Moreover, this gap in the debt ratio increases with the host country's statutory corporate tax rate.     

Tax compliance and firm response to electronic sales monitoring

This paper analyzes how firms respond to an Internet of Things technology that reduces significantly the tax authorities' marginal cost of monitoring firm activity. More precisely, we analyze how mandating every restaurant of a single Canadian province to have sales recording modules (SRMs) affects restaurant sales, expenses and profits. We estimate that SRMs increase reported sales by 5.8% to 9.8% on average and that this increase is almost completely offset by an equal increase in expenses, including wages. As a result, the firms' taxable income remains mostly unchanged. Our results suggest that sales tax remittance enforcement at the firm level spills over to other firm stakeholders, such as employees and suppliers. Overall, the one-time cost of the device needed to monitor sales more efficiently is small compared with the recurring benefits for tax authorities.     

Valuing Global Ecosystem Services: What Do European Experts Say? Applying the Delphi Method to Contingent Valuation of the Amazon Rainforest

Valuing global public goods like the Amazon rainforest by stated preference surveys of a representative sample of the global population would be very costly and time consuming. We explore the use of the Delphi Method in contingent valuation (CV) by asking a panel of 49 European environmental valuation experts in two rounds what they think would be the result if a European CV survey of Amazon Rainforest protection plans was conducted. The experts’ best guess for the mean willingness-to-pay (WTP) by European households for preserving the current Amazon Rainforest, and thus avoiding a predicted loss in forest area by 2050 from currently 85% to 60% of the original forest in the 1970s, was 28 € per household annually as an additional income tax. Aggregated over all European households this amounts to about 8.4 billion € annually. This preliminary estimate indicate that WTP of distant beneficiaries is substantial, and could justify preservation of global ecosystem services where aggregated benefits of the local population often do not exceed the opportunity costs of preservation in terms of lost income from commercial activities. The income elasticity of WTP with respect to per-capita income in the European countries is 0.5–0.6. Recognizing the limitations and assumptions of the Delphi CV method, it could still be a time saving and cost-effective benefit transfer tool for providing international donors with much needed order-of-magnitude estimates of the non-use value of ecosystem services of global significance.     

Using Elasticities to Derive Optimal Income Tax Rates

This paper derives optimal income tax formulas using compensated and uncompensated elasticities of earnings with respect to tax rates. A simple formula for the high income optimal tax rate is obtained as a function of these elasticities and the thickness of the top tail of the income distribution. In the general non-linear income tax problem, this method using elasticities shows precisely how the different economic effects come into play and which are the key relevant parameters in the optimal income tax formulas of Mirrlees. The optimal non-linear tax rate formulas are expressed in terms of elasticities and the shape of the income distribution. These formulas are implemented numerically using empirical earning distributions and a range of realistic elasticity parameters.     

Dividend Taxes and Income Shifting

In this paper, we analyze whether a dividend tax cut for owner‐managers of closely held corporations encourages income shifting, income generation, or both. We use rich Swedish administrative micro data from 2000 to 2011 comprising detailed firm‐ and individual‐level information. We find robust evidence of extensive income shifting across tax bases in response to the 2006 Swedish dividend tax cut. Owner‐managers of closely held corporations reclassify earned income as dividend income but do not increase total income. The response is more pronounced for owner‐managers with tax incentives and with easier access to income shifting through a high ownership share.     

How should a government finance pension benefits?

Based on an earlier report by Ono (2010), this paper presents consideration of a consumption tax and examines how tax reform to maintain the neutrality of pension benefits affects the income growth rate and the employment rate. A decrease in the rate of worker contribution (labour income tax rate) with an increase in a consumption tax raises employment, but the effect on income growth is ambiguous. A decrease in the rate of firm contribution with an increase in the consumption tax decreases employment and facilitates income growth. Therefore, if the unemployment rate must be decreased, then pension reform with a decrease in the rate of worker contribution should be selected. The results derived through the study described in this paper are consistent with the empirical facts. Moreover, for these analyses, we assume the other production function and confirm the robustness of the obtained results.     

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.     

两税合并、税收筹划与盈余管理方式选择

文章以2007年的两税合并为背景,研究上市公司出于税收筹划的目的如何选择盈余管理方式。研究发现,税率下降公司由于税率下降幅度较大,税收筹划收益较高,因此进行了显著向下的应计盈余管理,而没有选择真实盈余管理方式;而税率上升公司则由于存在5年的过渡期,税收筹划收益较低,因此既没有进行显著的应计盈余管理,也没有进行显著的真实盈余管理。这意味着上市公司在进行税收筹划时会综合权衡各种避税方式的成本收益,进而选择最合适的避税方式。政府部门在制定税收政策时必须预先考虑企业可能的税收筹划策略,以达到预期的政策效果。     

A macroeconomic analysis of sales and payroll tax cuts

This paper analyzes the short-run impact of sales and payroll tax cuts in a complete macroeconomic model which explicitly involves the government financing constraint. Sales and payroll tax cuts have been stressed as good measures for achieving once-for-all price level reductions. We demonstrate that in quite plausible circumstances, cuts in these taxes (financed by an increase in the personal tax rate) result in the price level increasing, not decreasing. Also, it is shown that a policy package involving a wage subsidy and a profits tax hike must involve employment and investment moving in the same, not the opposite, direction.     

A structural VAR approach on labour taxation policies

This paper presents a Structural VAR analysis on the employment and output effects of labour tax policies in six European countries for the period 1974–1997. By considering impulse response functions, it turns out that, on average, a shock to the total personal income tax revenues is positively correlated to employment, whereas there is mixed evidence on the output effect. Moreover, the quantitative impact of these effects, especially those related to the output, appears to be quite small. However, by introducing explicitly four labour tax parameters (namely the marginal and average tax rates for the personal income tax and the payroll tax), it turns out that these effects are not negligible after all: for some countries it is possible to conceive labour taxes as policy instruments favouring more employment and a better economic performance. However, the empirical support on the sign of the output and employment effects is mixed, suggesting that the same domestic fiscal policy does not produce the same impact in all the European countries.