Source versus residence based taxation with international mergers and acquisitions

• 成果类型: Article
• 署名作者: Becker, Johannes; Fuest, Clemens
• 署名单位: University of Oxford; Max Planck Society
• 刊物名称: JOURNAL OF PUBLIC ECONOMICS
• ISSN/ISSBN: 0047-2727
• DOI: 10.1016/j.jpubeco.2010.10.001
• 发表日期: 2011
• 页码: 28-40
• 关键词: Corporate taxation; Tax competition; Mergers and Acquisitions

摘要

This paper analyses tax competition and tax coordination in a model where capital flows occur in the form of mergers and acquisitions, rather than greenfield investment. In this framework, we show that differences in residence based taxes do not necessarily distort international ownership patterns. Moreover, tax competition yields globally efficient levels of source based corporate income taxes if residence based taxes on capital income are absent. In contrast, in the presence of residence based taxes on dividends, source based corporate income taxes are inefficiently high. The widespread view that tax coordination is less urgent if residence based taxes are available may therefore be misguided. (C) 2010 Elsevier B.V. All rights reserved.