Tax revenue losses through cross-border loss offset: An insurmountable hurdle for formula apportionment?

Mohammed Mardan, Michael Stimmelmayr

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This paper analyzes the relevance of firm losses for tax revenues and welfare when switching from separate accounting to a system of tax base consolidation with formula apportionment. We find that a system change unambiguously decreases tax revenues in the short run, in which neither firms nor governments can adjust their behavior, due to the cross-border loss offset inherent in formula apportionment. In the medium run, in which only firms can adjust their strategies, tax revenues are still lower under formula apportionment if the probability of incurring losses or the costs of profit shifting are sufficiently small. However, in the long run, where firms and governments can adjust their behavior, a switch from separate accounting to formula apportionment is beneficial under the aforementioned conditions. Furthermore, we show that a higher weight on input shares in the apportionment formula may mitigate tax competition and thus increase tax revenues because, contrary to output factors, input factors provide a backstop against a shortfall of tax revenues due to loss-making subsidiaries.
Original languageEnglish
Pages (from-to)188-210
Number of pages23
JournalEuropean Economic Review
Early online date25 Dec 2017
Publication statusPublished - 1 Feb 2018


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Michael Stimmelmayr

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