Tax Competition and International Public Goods

A well known result in the tax competition literature is that tax rates are set too low in the Nash equilibrium to finance an efficient level of public consumption goods. In this model we introduce international spillovers in public goods provision and show that such spillovers reduce, and in the limiting case of perfect spillovers, eliminate tax competition. There is, however, always underprovision of the public good in equilibrium, since larger spillovers increase the problem of free riding. In an extension to the model, we demonstrate that congestion costs may result in overprovision of the public good.     

Optimal Income Taxation and International Labour Mobility

This paper considers how a linear income tax should be set optimally when individuals are internationally mobile. The optimum tax analysis is founded on a social welfare function where each individual counts in the social welfare according to residence time in the home country. The discussion of the optimal income tax is organized from two perspectives. The first relates to the optimum income tax when a uniform lump sum transfer is used, while the second concerns the optimal rate of tax when a transfer is used which depends on time of residence in the taxing jurisdiction.     

Formula Apportionment and Transfer Pricing under Oligopolistic Competition

This paper demonstrates that under conditions of imperfect (oligopolistic) competition, a transition from separate accounting (SA) to formula apportionment (FA) does not eliminate the problem of profit shifting via transfer pricing. In particular, if affiliates of a multinational firm face oligopolistic competition, it is beneficial for the multinational to manipulate transfer prices for tax–saving as well as strategic reasons under both FA and SA. The analysis shows that a switch from SA rules to FA rules may actually strengthen profit shifting activities by multinationals.     

The Forward Premium in the Nord Pool Power Market

This article investigates the forward premium of futures contracts in the Nordic power market for the time period from January 2004 to December 2013. We find that futures prices are biased predictors of the subsequent spot prices and that there is a significant forward premium in the Nord Pool market, particularly during the winter and autumn. We analyze the impact from several factors on the forward premium. The spot price, and the deviation of water inflow from its usual level, positively affect the forward premium. The variance of the spot price also has a positive effect on the forward premium, but only for the contract closest to delivery.     

Transfer Pricing and Ownership Structure

We study the performance of jointly owned production units where upstream firms sell inputs to a downstream final market producer. It is found that, compared to integrated firms, co-ownership leads to overinvoicing of input prices (transfer prices), resulting in lower aggregate profits. Tax and tariff policy may lessen the organizational inefficiencies of jointly owned firms. The analysis suggests that firms must have other reasons for forming jointly owned production units than those guided by production efficiency and benefits from delegation of decision-making.
JEL classification: F 23; L 23     

Multinationals,Intra-Firm Trade and the Taxation of Foreign-Source Income

Most countries use the tax credit scheme instead of the tax deduction scheme to alleviate double taxation of foreign earnings. Under the tax deduction scheme, double taxation is alleviated by treating foreign taxes paid as business cost deductible against domestic income rather than allowing them to be credited against the taxes levied by the home country (as is the case under the tax credit system).This paper examines how the two tax systems affect trade between affiliates of a multinational firm.     

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.     

Debt shifting and ownership structure

Previous theoretical studies on the debt shifting behavior of multinationals have assumed affiliates of multinationals to be wholly owned. We develop a model that allows a multinational firm to determine both the leverage and ownership structure in affiliates endogenously. A main finding is that affiliates with minority owners have less debt than wholly owned affiliates and therefore a less tax-efficient financing structure. This is due to an externality that arises endogenously in our model, where costs and benefits of debt shifting are shared asymmetrically between minority and majority owners. Our findings provide a theory framework for recent empirical findings.     

Indirect taxation and tax incidence under nonlinear pricing

This paper study how a change in specific and ad valorem taxes under nonlinear pricing affects tax incidence. We show that an increase in either tax rate leads to a higher usage fee for all consumers, whereas the fixed fee under reasonable assumptions will fall. Finally, the model shows that the presumption in favor of ad valorem taxes over specific taxes also holds under nonlinear pricing and incomplete market coverage.     

Corporate tax systems and cross country profit shifting

The paper analyses optimal taxation of corporate profits whengovernments can choose both the rate and the base of the corporationtax, but are constrained to collect a given amount of corporatetax revenue. In a standard two-period model of investment andinternational mobility of portfolio capital only, the optimaltax system allows a full deduction for the costs of capital.When foreign direct investment is permitted, however, and firmscan shift profits between countries through transfer pricing,it will be optimal for each government to distort investmentdecisions in order to reduce tax rates and limit the incentivefor profit shifting.