Tax Losses and Ex-Ante Offshore Transfer of Intellectual Property

Rishi Sharma, Joel Slemrod and Michael Stimmelmayr

No 9262, CESifo Working Paper Series from CESifo

Abstract: We develop a positive model of multinational firm behavior and analyze a firm’s incentive to transfer an intellectual property (IP) right of uncertain value offshore ex ante, i.e. before its success or failure is realized. With an asymmetric treatment of losses in the home country, the multinational firm will transfer its IP to a foreign low-tax country to avoid potentially negative profits at home. In addition, similar incentives exist to transfer the IP to a jurisdiction where tax rates are comparable or even higher than at home if the foreign jurisdiction offers a more symmetric treatment of losses.

Keywords: intellectual property; corporate taxation; loss-offset; tax avoidance (search for similar items in EconPapers)
JEL-codes: D21 F23 H25 H26 (search for similar items in EconPapers)
Date: 2021
New Economics Papers: this item is included in nep-acc, nep-isf, nep-pbe and nep-pub
References: View references in EconPapers View complete reference list from CitEc
Citations: View citations in EconPapers (2)

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Related works:
Journal Article: Tax losses and ex-ante offshore transfer of intellectual property (2023)
Working Paper: Tax Losses and Ex-Ante Offshore Transfer of Intellectual Property (2023)
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Persistent link: https://EconPapers.repec.org/RePEc:ces:ceswps:_9262

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