Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/245443 
Year of Publication: 
2021
Series/Report no.: 
CESifo Working Paper No. 9262
Publisher: 
Center for Economic Studies and ifo Institute (CESifo), Munich
Abstract: 
We develop a positive model of multinational firm behavior and analyze a firm's incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. With an asymmetric treatment of losses in the home country, the multinational firm will transfer its IP to a foreign low-tax country to avoid potentially negative profits at home. In addition, similar incentives exist to transfer the IP to a jurisdiction where tax rates are comparable or even higher than at home if the foreign jurisdiction offers a more symmetric treatment of losses.
Subjects: 
intellectual property
corporate taxation
loss-offset
tax avoidance
JEL: 
H25
H26
D21
F23
Document Type: 
Working Paper
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