|
on Intellectual Property Rights |
Issue of 2018‒10‒01
four papers chosen by Giovanni Ramello Università degli Studi del Piemonte Orientale “Amedeo Avogadro” |
By: | Steffen Juranek; Dirk Schindler; Andrea Schneider |
Abstract: | The increasing use of intellectual property as a means to shift profits to low-tax jurisdictions or jurisdictions with so-called ‘patent boxes’ is a major challenge for the corporate tax base of medium- and high-tax countries. Extending a standard tax competition model for capital-enhancing technology, royalty payments, and profit shifting, this paper suggests a simple fix: It is optimal to set a withholding tax on (intra-firm) royalty payments equal to the corporate tax rate and deny any deductibility of royalties. As the tax applies to the full payment, the problem of identifying the arm’s-length component in a digital economy (OECD BEPS Action 1) does not apply. Most importantly, the denial of royalty deductions is the Pareto-efficient solution under coordination and the unilaterally optimal policy under competition for mobile capital. In the latter case, a weakened thin capitalization rule is a crucial part of the policy package in order to avoid negative investment effects. Our results question the ban of royalty taxes in double tax treaties and the EU Interest and Royalty Directive. |
Keywords: | source tax on royalties, tax competition, multinationals, profit shifting |
JEL: | H25 F23 |
Date: | 2018 |
URL: | http://d.repec.org/n?u=RePEc:ces:ceswps:_7227&r=ipr |
By: | Irani-Kermani, Roozbeh; Jaenicke, Edward C. |
Keywords: | Marketing, Research Methods/Statistical Methods, Demand and Price Analysis |
Date: | 2017–06–30 |
URL: | http://d.repec.org/n?u=RePEc:ags:aaea17:258203&r=ipr |
By: | AOUINI, Syrine; Gil, Jose M. |
Keywords: | Demand and Price Analysis, Marketing, Livestock Production/Industries |
Date: | 2017–06–15 |
URL: | http://d.repec.org/n?u=RePEc:ags:aaea17:258131&r=ipr |
By: | Mori, Tomoya; Sakaguchi, Shosei |
Abstract: | In this paper, we quantitatively characterize the mechanism of collaborative knowledge creation at the individual researcher level a la Berliant and Fujita(2008) by using Japanese patent data. The key driver for developing new ideas is found to be the exchange of differentiated knowledge among collaborators. To stay creative, inventors seek opportunities to shift their technological expertise to unexplored niches by utilizing the differentiated knowledge of new collaborators in addition to their own stock of knowledge. In particular, while collaborators' differentiated knowledge raises all the average cited count, average (technological) novelty and the quantity of patents for which an inventor contributes to the development, it has the largest impact on the average novelty among the three. |
Keywords: | Knowledge creation, Collaboration, Differentiated knowledge, Technological novelty, Technological shift, Recombination, Patents, Network, Strategic interactions |
JEL: | C33 C36 D83 D85 O31 R11 |
Date: | 2018–08–29 |
URL: | http://d.repec.org/n?u=RePEc:pra:mprapa:88716&r=ipr |