This study develops a model in which a multinational firm creates a brand that generates income in multiple countries. Many firms attempt to develop a brand, but only one firm succeeds. The firm that creates the brand earns positive residual profits. The industry as a whole does not, as the...

Tax planning with intangibles has become one of the most popular and most vividly debated topics in international taxation. We incorporate various intellectual property (IP) tax planning models into forward-looking measures of effective tax rates, namely the disposal of intangibles to low-tax...

This paper seeks to contribute to the current debate on EU-wide corporate taxation, steered by the impending Proposal by the European Commission on a new framework for the taxation of income of businesses in Europe. The objective of this paper is to verify whether the inclusion of intangible...

Numerous empirical studies have analysed the influence of corporate taxation on the location of intangible assets within a company group. However, the previous literature has rather focused on studying the impact of taxation on patent location choices assuming that these assets represent the...

We study the relation between patent concentration and tax-motivated income shifting. Using affiliate-level data for European multinational corporations (MNCs) and employing the relative share of patents held by an MNC as a measure for patent concentration, we predict and find that tax-motivated...

We study how the OECD transfer pricing guidelines aimed at curbing tax-motivated transfer pricing practices affect investment incentives. Our theoretical model integrates the different OECD's transfer pricing methods into the tax planning cost function of an MNC to evaluate how the choice of...

Advance pricing agreements (APAs) determine transfer prices for intra-firm transactions in advance. This paper interprets these contracts as a means to overcome a hold-up problem that occurs because governments cannot commit to non-excessive future tax rates. In addition, with private...

Advance pricing agreements (APAs) determine transfer prices for intra-firm transactions in advance. This paper interprets these contracts as a means to overcome a hold-up problem that occurs because governments cannot commit to non-excessive future tax rates. In addition, with private...

The article examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related foreign partner

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...