The impact of taxes on bilateral royalty flows

Olena Dudar, Christoph Spengel and Johannes Voget

No 15-052, ZEW Discussion Papers from ZEW - Leibniz Centre for European Economic Research

Abstract: In 2013 the OECD introduced its Action Plan on base erosion and profit shifting (BEPS). One of the major concerns of this Plan is a strategic use of intangible assets as an instrument for profit shifting. The main purpose of this paper is to test whether multinational enterprises use intangibles as an important BEPS channel by empirically analysing the relationship between taxation and bilateral royalty flows. We employ the OECD data on 3,660 country-pairs for the time period of 1990-2012 and apply the Poisson pseudo-maximum likelihood estimator in a fixed-effects framework. The main results point to a negative impact of taxation on bilateral royalty flows. Moreover, we find that tax differentials, which represent a relative level of taxation in a recipient state compared to other potential royalty recipients, have a significant influence on royalty payments as well. For tax policy considerations, the paper provides various insights to the ongoing work on BEPS by the G20, the OECD, and the European Commission. For example, we find that such reform suggestions of the OECD Action Plan as an enforcement of the Nexus Approach, as well as an introduction of strict Controlled Foreign Company rules and transfer pricing regulations are likely to reduce international royalty flows.

Keywords: royalty; intangible assets; tax planning; corporate taxation (search for similar items in EconPapers)
JEL-codes: F23 H25 H26 H3 (search for similar items in EconPapers)
Date: 2015
New Economics Papers: this item is included in nep-acc, nep-pbe and nep-pub
References: View references in EconPapers View complete reference list from CitEc
Citations: View citations in EconPapers (19)

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Persistent link: https://EconPapers.repec.org/RePEc:zbw:zewdip:15052

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