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Allowing Firms to Choose Between Formula Apportionment and Separate Accounting Taxation

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  • Thomas Gresik

Abstract

This paper analyzes the effect on firm behavior and national tax revenues of a policy of allowing multinational firms to choose whether to be taxed under separate accounting rules (transfer prices) or an apportionment formula. Either method can be preferred by low-cost firms and by high-cost firms, and the preferred method can vary non-monotonically with firm cost characteristics. Separate accounting always generates more profitable output and conditional labor demand distortions while either method can generate a more profitable income-shifting distortion. With asymmetric countries, country preferences are only partially aligned with firm preferences due to the fact that countries and firms value tax base distortions differently. With partial alignment of firm and country preferences, choice can increase tax revenues in both countries.

Suggested Citation

  • Thomas Gresik, 2013. "Allowing Firms to Choose Between Formula Apportionment and Separate Accounting Taxation," CESifo Working Paper Series 4560, CESifo.
    • Handle: RePEc:ces:ceswps:_4560
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    References listed on IDEAS

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    1. Søren Bo Nielsen & Pascalis Raimondos–Møller & Guttorm Schjelderup, 2003. "Formula Apportionment and Transfer Pricing under Oligopolistic Competition," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 5(2), pages 419-437, April.
    2. Gresik, Thomas A., 2010. "Formula apportionment vs. separate accounting: A private information perspective," European Economic Review, Elsevier, vol. 54(1), pages 133-149, January.
    3. Bauer, Christian J. & Langenmayr, Dominika, 2013. "Sorting into outsourcing: Are profits taxed at a gorilla's arm's length?," Journal of International Economics, Elsevier, vol. 90(2), pages 326-336.
    4. Mintz, Jack & Smart, Michael, 2004. "Income shifting, investment, and tax competition: theory and evidence from provincial taxation in Canada," Journal of Public Economics, Elsevier, vol. 88(6), pages 1149-1168, June.
    5. Thomas Eichner & Marco Runkel, 2008. "Why the European Union Should Adopt Formula Apportionment with a Sales Factor," Scandinavian Journal of Economics, Wiley Blackwell, vol. 110(3), pages 567-589, September.
    6. Thomas Gresik & Petter Osmundsen, 2008. "Transfer pricing in vertically integrated industries," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 15(3), pages 231-255, June.
    Full references (including those not matched with items on IDEAS)

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    More about this item

    Keywords

    formula apportionment; separate accounting; transfer prices;
    All these keywords.

    JEL classification:

    • H73 - Public Economics - - State and Local Government; Intergovernmental Relations - - - Interjurisdictional Differentials and Their Effects
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law

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