Please use this identifier to cite or link to this item: http://hdl.handle.net/10419/167550
Authors: 
Richter, Wolfram F.
Year of Publication: 
2017
Series/Report no.: 
CESifo Working Paper 6564
Abstract: 
Inter-country equity in the taxation of IP is a contentious issue. With its BEPS initiative, the OECD aims at taxing in accordance with value creation even though there are admitted difficulties in determining the actual place of value creation. The European Commission promotes the introduction of unitary taxation. The proposal’s drawback is that it lacks incentive compatibility in information exchange. Furthermore, it stipulates a cost-dependent apportionment of the common consolidated corporate tax base that incentivizes locating R&D in low-tax countries. Against this background, this paper makes a case for an internationally regulated split of the profit earned with imported IP.
Subjects: 
intellectual property
tax competition
profit split
formulary apportionment
Shapley value
JEL: 
H25
O34
M48
F23
Document Type: 
Working Paper

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