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Canadian Journal of Economics/Revue canadienne d économique
Article . 2023 . Peer-reviewed
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SSRN Electronic Journal
Article . 2018 . Peer-reviewed
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Research . 2018
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Conference object . 2018
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Royalty Taxation Under Tax Competition and Profit Shifting

Authors: S. Juranek; D. Schindler; A. Schneider;

Royalty Taxation Under Tax Competition and Profit Shifting

Abstract

Abstract Multinational corporations increasingly use royalty payments for intellectual property rights to shift profits globally. This not only threatens the tax base of countries worldwide but also affects the nature of tax competition. Against this background, our theoretical analysis suggests a surprising solution to the problem of curbing profit shifting without suffering major outflows of capital: a strictly positive withholding tax on royalty payments is both the Pareto‐efficient solution under international coordination and the optimal unilateral response. If internal debt is sufficiently responsive, governments can even implement optimal targeting. Then, the royalty tax closes the profit‐shifting channel, while all competition for mobile capital is relegated to internal‐debt regulation. Our results question the ban on royalty taxes in double tax treaties and the EU Interest and Royalty Directive.

Country
Netherlands
Keywords

source tax on royalties, ddc:330, H25, F23, tax competition, multinationals, profit shifting

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    popularity
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    influence
    This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
5
Top 10%
Average
Average
hybrid