Working Paper Revision

Taxation and the Global Allocation of Intangibles

Abstract: We study how international tax regimes affect the allocation of intangible assets using a new dataset on global patent transfers and a structural model of shifting decisions. Empirically, patent transfers respond strongly to statutory tax differentials during 2007–2012 but much less after major reforms. In the model, heterogeneous patents choose between licensing and shifting based on tax wedges and setup costs. Calibrated to observed shifting rates, the model matches the concentration of royalty income in low-tax jurisdictions. Counterfactuals show that harmonizing tax rates greatly reduces shifting and raises revenues, whereas modest minimum taxes have limited effects.

JEL Classification: F12; O33; O41; O47;

https://doi.org/10.20955/wp.2025.025

Bibliographic Information

Provider: Federal Reserve Bank of St. Louis

Part of Series: Working Papers

Publication Date: 2025-12-19

Number: 2025-025

Related Works

• Working Paper Revision (2025-12-19) : You are here.
• Working Paper Original (2025-09-29) : Taxation and the Global Allocation of Intangibles