TAXING FOREIGN PROFITS WITH INTERNATIONAL MERGERS AND ACQUISITIONS

• 成果类型: Article
• 署名作者: Becker, Johannes; Fuest, Clemens
• 署名单位: Max Planck Society; University of Oxford
• 刊物名称: INTERNATIONAL ECONOMIC REVIEW
• ISSN/ISSBN: 0020-6598
• DOI: 10.1111/j.1468-2354.2009.00575.x
• 发表日期: 2010
• 页码: 171-186
• 关键词: Optimal taxation; direct-investment; old rules; REFORM; POLICY; COMPETITION; realities

摘要

A large part of border crossing investment takes the form of international mergers and acquisitions. In this article, we ask how optimal repatriation tax systems look like in a world where investment involves a change of ownership, instead of a reallocation of real capital. We find that the standard results of international taxation do not carry over to the case of international mergers and acquisitions. The deduction system is no longer optimal from a national perspective and the foreign tax credit system fails to ensure global optimality. The tax exemption system is optimal if ownership advantage is a public good within the multinational firm. However, the cross-border cash-flow tax system dominates the exemption system in terms of optimality properties.