Headquarter relocations and international taxation

This paper examines the extent of international headquarter relocations worldwide . About 6 percent of all multinationals relocated their headquarter to another country in the 1997-2007 period. The paper presents empirical evidence on the role of tax in these relocation decisions. It considers a sample of 140 multinationals that relocated their head-quarters over the past decade and compares them to a control group of 1943 multinationals that have not done so. It is found that the additional tax due in the home country upon repatriation of foreign profits has a positive effect on the probability of relocation. The empirical results suggest that an increase in the repatriation tax by 10 percentage points would raise the share of relocating multinationals by 2.2 percentage points, equivalent to an increase in the number of relocations by more than one third. Furthermore, the introduction of controlled foreign corporation legislation also has a positive effect on the number of relocations.

Attention is increasingly being paid to the effects of corporation tax on the location of multinational headquarters. This research project addresses this issue. About 6 percent of all multinationals relocated their headquarters to another country between 1997 and 2007. We find that tax does play a role in these decisions. Based on a sample of 140 multinationals that relocated their headquarters over the past decade, and a control group of 1,943 multinationals that have not done so, we find that additional tax due in the home country upon repatriation of foreign profits has a positive effect on the probability of relocation. Specifically, empirical results suggest that an increase in the repatriation tax by 10 percentage points would raise the probability of relocation by 2.2 percentage points, equivalent to increasing the number of relocations by more than one third. The introduction of controlled foreign corporation legislation also has a positive effect on the number of relocations.

Johannes Voget