Do Transfer Pricing Rules distort R&D Investment Decisions?

This study analyzes the impact of transfer pricing on multinational enterprises' R&D investment decisions. Specifically, I examine the effects of two commonly used contract designs to exchange and develop intangible assets across group affiliates: licensing and cost sharing agreements. Whilst serving as a tool to allocate taxable income between group affiliates, the economic implications of licensing and cost sharing agreements differ. Whereas licensing agreements provide for a sharing rule on the intangible's profits, cost sharing agreements on the other hand provide a sharing rule on R&D development costs. This difference matters when firms simultaneously use internal transfer prices to allocate taxable income and provide local management with sufficient investment incentives. Using a multiple-agent, moral hazard investment framework I model a multinational firm with comparable group affiliates in two countries that delegates the R&D investment decision to a local risk and effort averse affiliate manager. The results suggest that the optimal contract not only depends on available tax benefits, but also on R&D investment and manager specific characteristics. A licensing agreement provides management with larger incentives to invest in R&D mitigating agency concerns associated with R&D. On the other hand, using a cost sharing agreement the firm can cater different risk preferences among managers potentially increasing investment. The arm's length principle however may distort an efficient allocation of R&D costs when using a cost sharing agreement.Series: WU International Taxation Research Paper Serie

Technology Transfer and Spillovers in International Joint Ventures

It is often argued that multinationals are reluctant to transfer technology due to the fear of spillovers. We show that this need not be the case if host country policies like taxation are taken into account. Furthermore, we examine the incentives the multinational and the host country have to engage in an international joint venture. We show why a multinational may agree to enter a joint venture even though this gives rise to spillovers. Surprisingly, we find that a joint venture is sometimes not in the interest of a host country, despite the prospect of spillovers

Technology Transfer and Spillovers in International Joint Ventures

This paper analyzes the effects of a potential spillover on technology transfer of a multinational enterprise and on the host country policy. In particular, we examine how both parties' incentives can be controlled through the ownership structure in an international joint venture. In contrast to existing arguments we show that spillovers must not always have negative effects on technology transfer and they may be efficiency improving. Moreover, there are circumstances where a joint venture is mutually beneficial. Surprisingly, however, we find that despite the prospect of spillovers a joint venture is sometimes not in the interest of a host country

A framework for the analysis of mineral tax policy in sub-Saharan Africa

Given the dual role played by the Government as resource owner and tax collector in many sub - Saharan economies, it is important to separate"resource factor payments"from taxes through the use of different instruments. The instruments to be considered are: (1) a factor payment system that includes"ad rem"or"ad valorem"royalties. Production sharing, resource rent schemes, and fixed fees could also be used, but some form of unit payment is necessary and justified, because natural resources in the ground are inputs into the production process; (2) a cash flow and withholding tax system initially for the mineral sectors and eventually for other sectors of the economy. The cash flow tax would capture a share of the"economic rent"from each sector and be neutral across sectors; and (3) a depletion account to preserve the nations capital stock. Natural resources are part of an economy's capital stock, which will fall unless"replacement investment"is made as the resource is depleted.Economic Theory&Research,Environmental Economics&Policies,Banks&Banking Reform,Public Sector Economics&Finance,Health Economics&Finance

Decentralized International Risk Sharing and Governmental Moral Hazard

This paper studies the issue of moral hazard in the presence of decentralized international risk sharing.In the model presented, risk sharing is achieved through macro markets (markets in which claims to the GDP of a country can be traded).Moral hazard arises for the following reason: if foreigners hold claims to domestic GDP due to risk sharing motives, the country will not receive the full benefit from its production anymore.This can motivate for example a tax on investment (which reduces production) or simply result in reduced governmental effort to increase productivity.We show in a two-country general equilibrium framework that the moral hazard problem does not lead to a reduction in the risk sharing (households hold half of world output).This results ultimately in a 100% tax on investment and creates a huge distortion.We conclude that unregulated macro markets pose a serious threat to world welfare.The analysis also raises concern about the desirability of decentralized risk sharing in general, in particular risk sharing through international trade of equity.moral hazard;international risk sharing

Optimal Taxation and Risk-Sharing Arrangements in an Economic Federation

This paper analyzes optimal taxation and risk-sharing arrangements in an economy with two levels of government. Both levels provide public goods and finance their expenditures via labor income taxation, where the tax base is responsive to the private agents' labor supply decisions. The localities are assumed to experience different random productivity shocks, meaning hat the private labor supply decisions as well as the choices of income tax rates are carried out under uncertainty. Part of the central overnment's decision problem is then to provide ax revenue sharing between the local governments. The optimal degree of revenue sharing depends on whether or not the localities/regions differ with respect to labor supply incentives.Optimal taxation; multilevel government; fiscal externalities; uncertainty; risk-sharing

Fiscal federalism and risk sharing in Germany: the role of size differences

We study the effect of size differences for an optimal risk sharing system of intergovernmental transfers in Germany. The German fiscal transfer system should account for the fact that an optimal insurance mechanism has the property that smaller states contribute a smaller share of their tax revenue to the redistribution mechanism. -- Wir betrachten die Rolle von Größenunterschieden von Gebietskörperschaften für einen optimalen Risikoausgleich im Rahmen eines föderalen Finanzausgleichs in Deutschland. Zunächst wird der Spielraum für einen möglichen Risikoausgleich durch interregionale Ausgleichszahlungen zwischen Gebietskörperschaften in Deutschland analysiert. Es zeigt sich, dass unsystematische Risiken insbesondere aus längerfristigen Entwicklungsunterschieden bestehen. Für das optimale Transfersystem sollte angesichts möglicher Anreizwirkungen solcher Systeme gelten, dass homogene Gebietskörperschaften einen um so größeren Anteil ihres Steueraufkommens in das interregionale Transfersystem einbringen sollten, je größer sie sind.Fiscal federalism,risk sharing,size asymmetry

Retirement Savings in an Aging Society: A Case for Innovative Government Debt Management

Aging societies will have to rely increasingly on private savings to finance retirement. The natural savings vehicles, stocks and bonds, are unfortunately lacking key risk-sharing features that are built into public retirement. Innovative government debt management can address this problem. The optimal policy supplies retirees with securities that share the financial risks of aggregate productivity, asset valuation, and demographic shocks across generations. As the population ages, state-contingent government bonds are a better risk sharing tools than pensions, which become too costly, or taxation, which raises time-consistency problems. Wage-indexed and longevity-indexed bonds in particular yield unambiguous efficiency improvements. To the extent that public pensions remain important, plans with wage-indexed defined benefits seem preferable to defined contributions or price-indexed plans. Capital income taxes and pension trust funds can play a supporting role for risk sharing.

Corporate Taxation and Corporate Governance

The effects of corporate taxation on firm behavior have been extensively discussed in the neoclassical model of firm behavior which abstracts from agency problems. As emphasized by the corporate governance literature, corporate investment behavior is however crucially influenced by diverging interests between shareholders and managers. We set up an agency model and analyze the crucial issue in corporate taxation of whether the normal return on investment should be exempted from taxation. The findings suggest that the divergence of interests may be intensified and welfare reduced if the corporate tax system exempts the normal return on investment from taxation. The optimal system may well use the full return on investment as a tax base. Hence, tax systems such as an Allowance for Corporate Equity (ACE) or a Cash-flow tax do not have the familiar efficiency-enhancing effects in the presence of corporate agency problems.corporate taxation, corporate governance, allowance for corporate equity, comprehensive business income tax, cash flow tax