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 pricing...

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 pricing...

I consider a continuum of multinational enterprises (MNEs), which differ in profitability. MNEs employ capital, shift profit to tax havens and may relocate their production facilities to other countries. Source countries provide public inputs and levy taxes. I derive optimal policy choices for...

The paper provides a critical review of the literature on the concept of progressivity in thetaxation of petroleum and mineral resources and offers a fresh perspective on its purpose andmeasurement. Regressive taxes, such as royalties, exist to satisfy policy objectives other thanrevenue...

Recent empirical studies find that foreign direct investment (FDI) by a multinational firm is not associated with a reduction of the firm's domestic activities. As it is often argued, this finding may imply that a country should not tax the firm's foreign profit income since this reduces foreign...

By introducing controlled-foreign-company (CFC) rules, the parent country of a multinational firm reserves the right to tax the income of the firm's foreign affiliates if the tax rate in the affiliate's host country is below a specified threshold. We identify the conditions under which binding...

Recent empirical studies find that foreign direct investment (FDI) by a multinational firm is not associated with a reduction of the firm’s domestic activities. As it is often argued, this finding may imply that a country should not tax the firm’s foreign profit income since this reduces...

What do models of optimal taxation imply about how multinationals should be taxed? Rather than focusing on a variety of neutrality conditions that have been proposed in the literature, this paper goes back to first principles and considers the overall role of the corporate tax. In doing so, the...

What is the optimal design of the international corporate tax system? We revisit this classic question in a multi-country general equilibrium model that incorporates three key features of the modern globalized economy: multinational production; intangible capital; and international profit...

We examine a multinational firm which has a decreasing marginal cost, and the optimal sales tax policies of the regions where that firm operates. We show that the regions set higher sales taxes than those given by a cooperative equilibrium. Each region fails to fully internalize the effects of...