No abstract

In 2014, 12 European countries are operating Intellectual Property (IP) Box regimes that provide substantially reduced rates of corporate tax for income derived from important forms of intellectual property. We describe the key features of the policies and incorporate them into forward-looking measures of the cost of capital and the effective average tax rate. We show that the treatment of expenses relating to IP income is particularly important in determining the effective tax burden. A key finding is that regimes that allow expenses to be deducted at the ordinary corporate income tax rate, as opposed to the lower IP Box tax rate, may result in negative effective average tax rates and can thereby provide a subsidy to unprofitable projects. We discuss the ways in which IP Boxes are likely to affect firms' decisions and relate this to possible policy aims. While some regimes attempt to link the tax benefit to real activities, others have designed a policy targeted at the income streams associated with intellectual property. A key concern is the role that IP Boxes may play in increased tax competition between European countries.

Die Dis cus si on Pape rs die nen einer mög lichst schnel len Ver brei tung von neue ren For schungs arbei ten des ZEW. Die Bei trä ge lie gen in allei ni ger Ver ant wor tung der Auto ren und stel len nicht not wen di ger wei se die Mei nung des ZEW dar.Dis cus si on Papers are inten ded to make results of ZEW research prompt ly avai la ble to other eco no mists in order to encou ra ge dis cus si on and sug gesti ons for revi si ons. The aut hors are sole ly respon si ble for the con tents which do not neces sa ri ly repre sent the opi ni on of the ZEW. Non-technical SummaryIntangible assets constitute a major input and value-driver for multinational firms. Often, the related intellectual property does not have a clear geographical location and firms use this flexibility to relocate IP and the associated income to low-tax countries in order to reduce their overall tax bill.Consequentially, tax legislators struggle with how to tax income from IP. In this regard, the most significant policy innovation in recent years has been the introduction of Intellectual Property (IP) Box regimes that offer a substantially reduced corporate tax rate for income derived from patents and other forms of IP. In Europe, 11 countries currently offer an IP Box with tax rates varying from 0% in Malta to 15.5% in France. We show that IP Boxes produce substantial reductions in the effective tax burden of profitable investment projects, and in some cases the burden on investment projects that just break even (so called marginal investment). A key finding is that the treatment of expenses relating to IP income is generally more decisive for the effective tax burden than the nominal IP Box tax rate. The treatment of expenses can be sufficiently generous that IP Boxes provide negative effective tax rates, indicating that unprofitable investment projects are subsidised by the regime.We discuss whether IP boxes are likely to affect real behaviours, specifically the amount and location of R&D investments. We conclude that, when taking into account the large degree of uncertainty associated with new R&D projects, IP Boxes are poorly-targeted at incentivising firms to undertake additional R&D investments. IP Boxes may work to attract mobile investments, and in theory could increase tax revenues. However, any positive effects might be eroded by the operation of similar policies by other countries. Das Wichtigste in Kürze Abstract:11 European countries now operate IP Box regimes that provide substantially reduced rates of corporate tax for income derived from important forms of intellectual property. We incorporate these policies into forward-looking measures of the cost of capital, effective marginal tax rates and effective average tax rates. We show that the treatment of expenses relating to IP income is particularly important in determining the effective tax burden. A key finding is that regimes that allow expenses to be deducted at the ordinary corporate income tax rate, as opposed to the IP Box tax rate, may result in negative tax rates a...

This paper asks when a wealth tax would in principle be a desirable part of the tax system, setting aside the practicalities and politics that would be crucial in reality. The case for a one-off wealth tax is simple. If it were unexpected and credibly one-off -a major challenge in practice -this would be an efficient way to raise revenue and could be used to address existing wealth inequality. Whether such a tax is desirable hinges on whether it is considered fair, about which reasonable people will differ. Making the case for an annual wealth tax, which would affect future wealth accumulation as well as existing wealth, is less straightforward. It requires explaining why it is better to tax the same wealth every year -penalising those who saverather than raising the same revenue by taxing all sources of wealth once when they are received (and/or when they are spent). Such a case can be made based on subtle arguments for why taxing wealth might help to ease the trade-off between redistribution and work incentives; and a wealth tax might also be justified if holding onto wealth, rather than spending it, benefits the holder or harms others. These theoretical arguments probably justify some taxation of wealth in principle, though we have little basis for judging the appropriate level, so only part of the theoretical benefit could be attained. It is questionable whether the achievable benefits outweigh the costs of an imperfect wealth tax in practice.There are strong reasons to radically reform how we currently tax the sources/uses of wealth; this includes reforming capital income taxes in order to properly tax high returns. An annual wealth tax would be a poor substitute for doing that. But to the extent that taxes remain imperfect and that responses to a wealth tax would not affect revenue from other taxes (such as on income, expenditure and bequests), there may be a benefit to adding a wealth tax in order to diversify sources of revenue and prevent any one tax getting too high -though that must be weighed against the extra administrative burdens of having another tax.

The level of private sector labour productivity has been particularly weak since the start of the crisis. In this paper we explore whether impairment to capital reallocation has been contributing to this weakness. The recent increase in the dispersion of output, prices and rates of return across firms and sectors is stark, and suggests that resources have had incentives to move. Efficient allocation requires that capital moves to firms and sectors where rates of return are relatively high. And the change in capital levels across sectors has been particularly low, suggesting there has been an unusually slow process of capital reallocation since 2008 compared to previous UK recessions and other banking crises. This result is also apparent within sectors. We use a simple and general model to show that increased price dispersion can be a consequence of frictions to efficient capital allocation. And the size of this dispersion can usefully inform us about the size of the associated output and productivity loss. We then find that – using firm level data – the relationship between rates of return and subsequent capital movements has changed since the financial crisis. Overall, our results suggest that impaired capital reallocation across the UK economy is likely to have been one factor contributing to the recent weakness in productivity growth.