The taxation of labour vs. capital income: A focus on high earners

Authors: Diana Hourani, Bethany Millar-Powell, Sarah Perret and Antonia Ramm

This working paper presents novel analysis comparing in a consistent way the tax treatment of labour and capital income across OECD countries, through stylised effective tax rates (ETRs). It shows that dividend income and capital gains are generally subject to lower ETRs than wage income at the personal level. In many countries, capital income is also tax-favoured even when considering taxes paid by both firms and individuals, although the gap between labour and capital income taxation tends to be smaller than when considering only personal-level taxes. The gap between ETRs on labour and capital income varies between countries and grows with income levels in some. The paper highlights that differential tax treatment of labour and capital income can affect the efficiency and equity of tax systems.

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Tax and investment by multinational enterprises

Authors: Tibor Hanappi and David Whyman

This paper investigates two closely related questions concerning the responses of Multi-National Enterprise (MNE) investment to corporate income taxation using a panel of unconsolidated subsidiary-level and consolidated group-level data from the ORBIS database. First, the paper provides new evidence on the heterogeneity of investment responses to taxation across multinational firms. This paper finds that profit shifting opportunities, access to credit, and market power at the group level are associated with decreased investment sensitivity to taxation among MNE subsidiaries. Second, a new empirical approach is used to investigate how tax changes at the host jurisdiction level affect investment at the MNE group level and whether there are propagation effects to foreign subsidiaries within the same MNE group. This paper finds that taxation in one jurisdiction in which an MNE is active is positively associated with investment in its subsidiaries in other jurisdictions. This finding suggests that the well-document negative relationship between taxation and MNE investment within a host jurisdiction masks the MNE rebalancing the location of its investment to other host jurisdictions in response to changes in cross-jurisdictional tax rate differentials rather than purely decreasing its investment globally.

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Effective tax rates for R&D intangibles

Authors: Ana Cinta González Cabral, Tibor Hanappi, Silvia Appelt, Fernando Galindo-Rueda and Pierce O’Reilly

Tax incentives such as intellectual property regimes provide for reduced taxation of the income derived from research, development, and innovation related activities. By doing so, they lower the overall tax burden from investing in certain qualified intangible assets. This paper proposes a methodology to build indicators comparing the effect of income-based tax incentives for R&D and innovation on firms’ incentives to make R&D intangible investments. It provides insights into how such incentives affect firms’ decisions on whether, where and how much to invest in R&D intangibles. These indicators are used to illustrate the extent to which these tax incentives may create potential distortions to firms’ investment, protection and commercialisation decisions. The model is further developed to account for the design changes to such tax incentives introduced by the OECD/G20 Base Erosion and Profit Shifting minimum standard.

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A time series perspective on income-based tax support for R&D and innovation

Authors: Ana Cinta González Cabral, Silvia Appelt, Tibor Hanappi, Fernando Galindo-Rueda, Pierce O’Reilly and Massimo Bucci

The use of tax incentives that provide preferential tax treatment to the incomes arising from research and development (R&D) and innovation activities, such as intellectual property regimes, has accelerated over the last two decades. The globalisation of R&D together with the greater mobility of intangible income may have contributed to the rise in such incentives to attract and retain R&D and innovation activity while preventing the transfer of taxable base to other countries. This paper documents the changes to the availability and design of income-based tax incentives from 2000 onwards for 48 countries, including all OECD countries and EU countries. Building on this, the paper analyses trends in the generosity of income-based tax support over time by building indicators of effective tax rates that can provide insights into the impact of Action 5 of the OECD/G20 Base Erosion and Profit Shifting project.

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