Taxation and International Capital Asset Pricing Theory

Adler and Dumas (1983) laid the foundation for pricing international assets under deviation from Relative Purchasing Power Parity (PPP). Only Lally (1996) regards the spectrum of international taxation but in his model - he disregards the tremendous impact of exchange gains taxation in International Capital Asset Pricing Theory (IntCAPT). Furthermore, the consensus in economic literature that exchange rates show evidence of a non-linear behavior as elaborated by Dumas (1992), Grauwe (1993) and Serçu and Uppal (1995) and that monetary policy ultimately determines inflation as determined by McCallum (1990) is ignored. In addition to this, a realistic version of the Tax International Capital Asset Pricing Model (Tax - IntCAPM) should incorporate the fact that dividends are stochastic, as developed in the Tax Capital Asset Pricing Model (Tax - CAPM) of Lally (1998), Wiese (2006b) and Mai (2006a).This dissertation develops a theory of taxation in pricing international assets. To understand this theory, in the first part we introduce and discuss the research question and the conceptual procedure of the dissertation. The review of the status of research provides an extensive overview on research pertaining to taxation in IntCAPT. In the second part, the framework of international taxation is introduced, and by introducing the features of exchange gains taxation a new income type in IntCAPT is presented. The analysis of the international tax system with the features of exchange gains taxation leads to the new result that under the hypothesis of Relative PPP certain constellations of international taxation lead to a Tax-IntCAPM that would be equal to the Tax - CAPM. With the features of exchange gains taxation and the modeling of deviation from Relative PPP by non-linear behavior of exchange rate and inflation determined by monetary policy, an extended model of taxation in IntCAPT - the Tax - IntCAPM - is developed and interpreted. The new result is that the integration of exchange gains taxation into the Tax - IntCAPM leads to an international pricing relationship composed of the risky asset's excess return and its world risk premium, which is adapted by exchange gains tax factors. The non-linear deterministic behavior of exchange rates and the determination of inflation by monetary policy lead to the integration of the market equilibrium exchange and inflation rate into the Tax - IntCAPM. International tax arbitrage opportunities lead to the derivation of the Tax - IntCAPM under short sale and borrowing restrictions. To implement this new international capital market model, the Tax - IntCAPM with homogeneous expectations is derived and interpreted. The third part concludes the dissertation with an extensive critique elaborating the boundaries of the models and a conclusion summarizing the main results and analyzing the implications of the findings.