Intangibles exhibit zero marginal licensing cost, including cross-border intra-firm licensing of intangibles within a multinational corporation (MNC). An MNC may not realise the full profit potential of licensing intangibles intra-firm, however, under suboptimal negotiated transfer pricing...

We study the relation between patent concentration and tax-motivated income shifting. Using affiliate-level data for European multinational corporations (MNCs) and employing the relative share of patents held by an MNC as a measure for patent concentration, we predict and find that tax-motivated...

Large multinational companies are regularly suspected of using transfer pricing of intangibles to shift profits from high- to low-tax jurisdictions. We study the optimal transfer prices while endogenizing the location choice of intangibles and considering spillovers. In line with the initial...

This paper assesses the effect of international differences in taxes on the choice of patent location by multinational enterprises (MNEs). The analysis is based on a large sample of patents and firms from the OECD-PATSTAT and OECD-ORBIS databases over 2004-10. The approach is to compare the...

We provide indirect empirical evidence of profit shifting behavior by multinational enterprises. This issue is analyzed in an econometric panel study for the years 1995 to 2005 and additionally in a cross-section for 2004 using a large micro database of European subsidiaries of multinationals...

Ownership structures of multinational enterprises are commonly assumed to remain constant over time, both due to a lack of easily accessible panel data and to facilitate empirical analyses. This paper discusses the validity of this assumption and assesses its relevance in the context of profit...

Much of the foreign direct investment worldwide is affected by one of more than 3000 bilateral tax treaties. There is an agreement that dividend and interest payments respond to these tax treaties' provisions, but evidence is scarce as to the magnitude of this response. We aim to fill in this...

We develop a new methodology to decompose the observed decline in multinational corporations' (MNCs') effective tax rates into profit shifting to tax havens and several other components. We apply this methodology to the best available data for MNCs headquartered in the US - from the Bureau of...

Multinational enterprises make use of tax havens to avoid paying corporate income taxes and this costs hundreds billion USD in lost government revenue worldwide according to an increasing number of recent studies. None of those studies assigns these costs to industries. I aim to shed more light...

This paper examines the determinants and margins of profit shifting through transfer pricing. We develop a theory model, where transfer pricing patterns are governed by a generalized concealment cost function (CCF). Our empirical analysis draws on micro-level data about transaction-level...