Unilateral Introduction of Destination Based Cash Flow Taxation
17 Pages Posted: 16 Nov 2018
Date Written: October 26, 2018
We analyze the unilateral introduction of a destination-based corporate cash-flow tax system (DBT), as recently proposed by Auerbach and Devereux (AEJ Policy 2018). We show that, first, the DBT rate is decision-neutral only if the source-tax country makes the DBT payments deductible from its tax base. Second, a unilateral DBT introduction is, in many aspects, equivalent to completely abolishing the corporate tax and, instead, taxing domestic investors based upon their worldwide profit income, net of foreign taxes and on accrual. In this sense, the DBT is actually a pure residence based tax. This implies that, from a foreign investor's perspective, the DBT country is like a zero-rate tax haven and has the same gravitational power on taxable (and shiftable) profits and economic activity. The location of profit and activity within its borders is, however, without any fiscal value for the DBT country. Third, the introduction of a DBT system reduces national income. Finally, the DBT country can only individually benefit from its new tax system if public goods provision is substantially increased.
Keywords: business taxation, destination taxation, tax competition
JEL Classification: H25, H32, H87
Suggested Citation: Suggested Citation