The Samuelson tax is a neutral business income tax on the normal return on capital only. I discuss two modifications of the Samuelson tax in order to include pure profits in its tax base, but still achieve neutral business taxation.

Using a firm-level panel data set this paper investigates the impact of taxation on the decision of German multinationals to hold or establish a subsidiary in other European countries or abroad. Taking account of unobserved local characteristics as well as firm-specific preferences for potential...

The paper evaluates the working of German CFC rules that restrict the use of foreign subsidiaries located in low-tax countries to shelter passive investment income from home taxation. While passive investments make up a significant fraction of German outbound FDI, we find that German CFC rules...

This paper evaluates three possible explanations for why empirical studies have found a quite moderate response of multinationals' capital structure to tax incentives. Firstly, by concentrating on debt decisions by operating subsidiaries, previous studies may have overlooked the importance of...

In its Cadbury-Schweppes decision of 12 September 2006 (C-196/04), the Court of Justice of the European Union decided that the UK controlled foreign corporation rules, which were implemented to subject low taxed passive income of foreign affiliates to UK corporate tax, implied an infringement of...