Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf ·...

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Comments on Steve Bond “Business tax incentives” Thiess Buettner Univ. of Erlangen-Nuremberg & CESifo ECFIN Taxation Workshop: 23 October 2013 BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 1 / 10

Transcript of Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf ·...

Page 1: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Comments on Steve Bond “Business tax incentives”

Thiess Buettner

Univ. of Erlangen-Nuremberg & CESifo

ECFIN Taxation Workshop: 23 October 2013

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 1 / 10

Page 2: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review

Concept of tax expenditures difficult to apply to business tax incentives

• Standard tax base discriminates◦ against investment◦ between different sources of finance

• Fundamental tax reform (ACE) would show up as tax expenditures...

• ... and would call into question the classification of other taxexpenditures (accelerated depreciation)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 1 / 10

Page 3: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review

Concept of tax expenditures difficult to apply to business tax incentives

• Standard tax base discriminates◦ against investment◦ between different sources of finance

• Fundamental tax reform (ACE) would show up as tax expenditures...

• ... and would call into question the classification of other taxexpenditures (accelerated depreciation)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 1 / 10

Page 4: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review

Concept of tax expenditures difficult to apply to business tax incentives

• Standard tax base discriminates◦ against investment◦ between different sources of finance

• Fundamental tax reform (ACE) would show up as tax expenditures...

• ... and would call into question the classification of other taxexpenditures (accelerated depreciation)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 1 / 10

Page 5: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review, cont.

• Bonus depreciation might

◦ stimulate investment, but ...◦ ... timing issues, political problems, other solutions.

• R&D tax credit might

◦ contribute to growth, but ...◦ ... full expensing, definition, capitalizaton, patent boxes.

• Measures targeting SME’s might

◦ be justified for start-ups, but ...◦ ... low productivity, other sources for risk, many other policies.

in dubio contra reum

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 2 / 10

Page 6: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review, cont.

• Bonus depreciation might

◦ stimulate investment, but ...◦ ... timing issues, political problems, other solutions.

• R&D tax credit might

◦ contribute to growth, but ...◦ ... full expensing, definition, capitalizaton, patent boxes.

• Measures targeting SME’s might

◦ be justified for start-ups, but ...◦ ... low productivity, other sources for risk, many other policies.

in dubio contra reum

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 2 / 10

Page 7: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review, cont.

• Bonus depreciation might

◦ stimulate investment, but ...◦ ... timing issues, political problems, other solutions.

• R&D tax credit might

◦ contribute to growth, but ...◦ ... full expensing, definition, capitalizaton, patent boxes.

• Measures targeting SME’s might

◦ be justified for start-ups, but ...◦ ... low productivity, other sources for risk, many other policies.

in dubio contra reum

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 2 / 10

Page 8: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Review, cont.

• Bonus depreciation might

◦ stimulate investment, but ...◦ ... timing issues, political problems, other solutions.

• R&D tax credit might

◦ contribute to growth, but ...◦ ... full expensing, definition, capitalizaton, patent boxes.

• Measures targeting SME’s might

◦ be justified for start-ups, but ...◦ ... low productivity, other sources for risk, many other policies.

in dubio contra reum

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 2 / 10

Page 9: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Business Tax Incentives & Mobility

Alternative rationale for business tax incentives

• Relocation of economic activities

• Tax competition: conflict between government rational andeconomic efficiency

Case of state tax incentives in the US

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 3 / 10

Page 10: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Business Tax Incentives & Mobility

Alternative rationale for business tax incentives

• Relocation of economic activities

• Tax competition: conflict between government rational andeconomic efficiency

Case of state tax incentives in the US

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 3 / 10

Page 11: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

State Investment Tax Credits in the US

State investment tax credits: number of states with a credit (left vertical axis) andaverage credit rate (right vertical axis) 1969 to 2004. Notes: Average credit rate isthe average statutory investment tax credit rate among those states in a given yearthat have an investment tax credit. Tabulated investment tax credits (ITCs) includeonly general, statewide ITCs. Source: Chirinko and Wilson (2008).

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 4 / 10

Page 12: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

State Investment Tax Credits vs Statutory Tax Rates

Top marginal tax rate and average investment tax credit calculated over all 50 states(unweighted) excluding the District of Columbia. Source: Chirinko and Wilson (2011).

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 5 / 10

Page 13: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

State Investment Tax Credits: Explanations

• Positive interpretation:campaign contributions (Chirinko and Wilson, 2010)

• Normative interpretation:discrimination of immobile vs. mobile investment (Wildasin, 2008)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 6 / 10

Page 14: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

State Investment Tax Credits: Explanations

• Positive interpretation:campaign contributions (Chirinko and Wilson, 2010)

• Normative interpretation:discrimination of immobile vs. mobile investment (Wildasin, 2008)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 6 / 10

Page 15: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Location Incentives: International

Theoretical predictions

• International capital mobility (FDI):reductions in tax burden to stimulate location

Average tax burden matters and tax depreciation less important

• Internationalization of R&D:R&D tax incentives to attract R&D

Consistent with empirical trends in taxation(e.g., Devereux, Griffith, Klemm, 2002)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 7 / 10

Page 16: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Location Incentives: International

Theoretical predictions

• International capital mobility (FDI):reductions in tax burden to stimulate locationAverage tax burden matters and tax depreciation less important

• Internationalization of R&D:R&D tax incentives to attract R&D

Consistent with empirical trends in taxation(e.g., Devereux, Griffith, Klemm, 2002)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 7 / 10

Page 17: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Location Incentives: International

Theoretical predictions

• International capital mobility (FDI):reductions in tax burden to stimulate locationAverage tax burden matters and tax depreciation less important

• Internationalization of R&D:R&D tax incentives to attract R&D

Consistent with empirical trends in taxation(e.g., Devereux, Griffith, Klemm, 2002)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 7 / 10

Page 18: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Location Incentives: International

Theoretical predictions

• International capital mobility (FDI):reductions in tax burden to stimulate locationAverage tax burden matters and tax depreciation less important

• Internationalization of R&D:R&D tax incentives to attract R&D

Consistent with empirical trends in taxation(e.g., Devereux, Griffith, Klemm, 2002)

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 7 / 10

Page 19: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Location Incentives: Assessment

• Rational policy for individual governments

• General equilibrium perspective points at ineffectiveness andinefficiencies

• Location tax incentives open up profit-shifting opportunities

• Countries are increasingly concerned with limiting these opportunities

• Emergence of loss offset restrictions and thin-capitalization rules

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 8 / 10

Page 20: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Thin-Capitalization Rules among EU-28

(Blue line: share of countries imposing thin-capitalization rules. Red line: mean debt-equity ratio in these countries. Source: Buettner et al. (2012). )

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 9 / 10

Page 21: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Summary

• Not all business tax incentives are inefficient, but

• location tax incentives are associated with tax competitioninefficiencies

• ... and force governments to introduce further tax distortions

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 10 / 10

Page 22: Business tax incentives - European Commissionec.europa.eu/...ecfin_workshop/pdf/buettner_en.pdf · 10/23/2013  · Average tax burden matters and tax depreciation less important Internationalization

Summary

• Not all business tax incentives are inefficient, but

• location tax incentives are associated with tax competitioninefficiencies

• ... and force governments to introduce further tax distortions

BUETTNER (U.of Erlangen-Nuremberg) Comments ECFIN Taxation Workshop 10 / 10