Intangibles exhibit zero marginal licensing cost, including cross-border intra-firm licensing of intangibles within a MNC. A MNC may not realize the full profit potential of licensing intangibles intra-firm, however, under suboptimal negotiated transfer pricing schemes. Our negotiated transfer...

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...

When multinationals face lower tax rates abroad than in the US, transfer pricing strategies generate an asymmetry in the tax rates on a project's profits and losses. We show that the tax savings from transfer pricing can be expressed as a long position in a call option. We use a model to show...

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...

Using confidential data on the foreign operations of US multinational firms, I examine innovation in the context of an unexpected policy shock that facilitated foreign tax arbitrage. I find that after the shock, US multinationals shifted more of their intellectual property and taxable income to...

In 2015, changes to Irish tax legislation, known as the "2015 Finance Act", coincided with a 26% annual increase in real gross domestic product. We show evidence confirming the conclusions of existing literature, which suggests that the presence of large multinational enterprises (MNEs) is...

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...

The adequate pricing of intellectual property (“IP”) for tax reporting is a largely unsettled issue. Transactional profit-based methods are on the rise although only rated as “methods of last resort” by the OECD. This paper focuses on regulated profit splitting and compares this transfer...

Patent boxes have been heavily debated for their role in corporate tax competition. This paper uses firm-level data for the period 2000-2011 for the top 2,000 corporate research and development (R&D) investors worldwide to consider the determinants of patent registration across a large sample of...