CORPORATE TAX GAMES WITH CROSS-BORDER EXTERNALITIES FROM PUBLIC INFRASTRUCTURE.
Dewit, Gerda ; Hynes, Kate ; Leahy, Dermot 等
CORPORATE TAX GAMES WITH CROSS-BORDER EXTERNALITIES FROM PUBLIC INFRASTRUCTURE.
I. INTRODUCTION
As economic globalization deepens, countries tend to compete
fiercely with each other to attract foreign direct investment (FDI),
often using favorable tax rates. This is evident both from the often
heated political debate on corporate taxes (1) and has also been
emphasized by the vast academic literature on tax competition. While the
tax rate in the prospective host location matters for a firm's
location decision, its actual location choice typically hinges on a
combination of host location characteristics, among which infrastructure
plays a prominent role (as shown by Brakman, Garretsen, and van
Marrewijk 2002 and suggested in earlier theoretical work, e.g., Taylor
1992). (2)
In this article, we focus on the role of public infrastructure when
there is tax competition. In doing so, we address two questions. First,
we examine how governments' investment decisions in public
infrastructure interact with their policy of corporate taxation. Second,
as the possibility of tax harmonization has been on the political agenda
for a long time now and seems even more pressing as globalization
deepens, we explore how tax harmonization between two competing host
countries affects those countries' investment in public
infrastructure and their welfare.
Our article relates to three different strands in the literature.
First and foremost, it fits in the literature that deals with
competition for international firms. The bulk of this literature is
concerned with tax competition. Following the theoretical work of Wilson
(1986), empirical work provides strong evidence for tax competition
between jurisdictions (e.g., Devereux, Lockwood, and Redoano 2008). (3)
Other work--albeit smaller in volume--has focused on infrastructural or
public goods-related competition between jurisdictions to attract
foreign firms and argues that this may lead to an overprovision of
public goods. (4) More recent work examines the link between tax rates
and the provision of public goods when countries use both these policy
instruments to compete for FDI. Notable examples of theoretical work are
Zissimos and Wooders (2008), Hindriks, Peralta, and Weber (2008),
Dembour and Wauthy (2009), and Pieretti and Zanaj (2011). (5) Empirical
work addressing the joint impact of tax rates and public inputs as
determinants for attracting foreign firms is still small but growing.
Benassy-Quere, Gobalraja, and Trannoy (2007) conclude that both the
corporate tax rates and the public capital stock mattered for FDI by
American firms into European countries. Gorg, Molana, and Montagna
(2009) use Organisation for Economic Co-operation and Development (OECD)
data and find that high corporate tax rates do not necessarily dampen
FDI if associated with the provision of public goods that improve the
economic environment in which multinational firms operate. (6) Recent
empirical work provides direct evidence that governments are using
public infrastructure together with corporate tax rates to attract
mobile capital. This includes Gomes and Pouget (2008), who show that
corporate tax rates and public investment are endogenous and also find
evidence for international competition in both policy instruments. In a
study that looks at German regions, Hauptmeier, Mittermaier, and Rincke
(2012) focus on the strategic interaction between governments that not
only choose corporate tax rates but also public inputs. They find that
not only the strategic interaction effect between jurisdictions is
significantly positive for tax rates, but also the direct interaction
effect between jurisdictions is statistically different from zero for
public input provision. In fact, it tends to be even larger than the
direct interaction effect in taxes capital. These studies point to the
deliberate use of both tax rates and public infrastructure provision to
attract mobile capital.
Second, our model contributes to the literature on cross-border
effects of public infrastructure. The nature of the externalities and in
particular whether they are beneficial or harmful to neighboring
countries or regions, depends both on the specific regions involved as
well as on the type of public infrastructure. From a theoretical point
of view, given two jurisdictions' relative attractiveness,
infrastructure investment in one of the jurisdictions makes it more
attractive to multinational firms and hence potentially has a
"business-stealing" effect on the other region. Even if the
investment in infrastructure in one region is not just local in that it
connects its transport or telecommunications network to those in the
other region, the latter does not necessarily benefit from that
investment. Martin and Rogers (1995) distinguish between a
country's investment in domestic and international infrastructure
in a theoretical model without tax competition and emphasize the
different effects of the two types of public infrastructure for firm
location. Surveying the empirical evidence, Puga (2008) concludes that
infrastructure investment projects generate externalities that may
diffuse over wide geographical areas. Boarnet (1998) and Moreno and
Lopez-Bazo (2003) find evidence of public infrastructural investment
having harmful effects on surrounding regions for Canada and Spain,
respectively. By contrast, Cohen and Morrison Paul (2003) and Cohen and
Morrison Paul (2003, 2004) present evidence of positive spatial
spillovers of public infrastructure between U.S. states. (7) Yu et al.
(2012) present evidence for China, suggesting that public infrastructure
spillovers are positive between some regions, negative between others,
and zero for yet other regions. Naturally, cross-border externalities
are also relevant across nations. Consider, for instance, how ports and
airports in one country will affect other countries (see Dembour and
Wauthy 2009). (8) In short, the empirical literature offers evidence for
negative and positive cross-border spillovers of public infrastructure
investment.
Third, our work is also related to the literature on globalization
and public spending. There is a growing literature that, contrary to
conventional wisdom, globalization does not necessarily imply that
public spending will fall. Rodrik (1998) provides empirical evidence for
a positive relationship between the degree of openness of a country and
the size of its government. (9) Our paper shows that the footlooseness
of multinational firms does not necessarily imply a low level of public
infrastructure investment. (10) If governments invest in public
infrastructure to attract mobile capital, this could result in an
overprovision of those types of infrastructure that are of most interest
to mobile firms with possible ramifications for public spending geared
toward immobile residents. This potential side effect of using public
infrastructure to attract mobile capital was predicted in the
theoretical literature by Keen and Marchand (1997). In their words,
"Crudely put, the picture that emerges is thus one in which fiscal
competition leads to too many business centres and airports but not
enough parks and libraries." (11) More recently, Winner (2012)
finds evidence for just such a bias in the composition of public
spending. Specifically, he examines whether infrastructural competition
affects the composition of public spending, using data from 18 OECD
economies (from 1980 to 2000). He provides support for the hypothesis
that infrastructural competition will affect the composition of public
spending and cause a shift from residential public goods to industrial
public inputs, where the former benefit immobile residents and the
latter benefit mobile production factors.
In this article, we characterize government strategies to attract
footloose capital, taking into account the interdependence between
corporate taxes and public infrastructure investment. Our model
considers two jurisdictions, which compete for foreign firms in a
two-stage game: they commit to public infrastructure levels in stage
1--which captures the long-term nature of this investment decision--and
compete for FDI with corporate taxes in stage 2.
Our analysis is different in various respects from previous works
and contributes to the aforementioned literature in several ways. First,
unlike the setup in these papers, our framework allows for positive and
negative cross-border spillovers from public infrastructure. (12)
Second, our model captures the fact that the game that countries
play is rarely a zero-sum one: competing for business with lower taxes
or higher infrastructure can be expected to lead to an increase in the
total pool of FDI and to enhance the combined tax base of the competing
countries. (13) This modeling innovation is likely to be relevant for
future empirical work that aims to measure the success of policy
packages designed to attract FDI. Also important in this respect is that
our work generalizes the model beyond specific functional forms.
Third, we examine a form of tax harmonization that should not just
eliminate the harmful race-to-the-bottom in tax rates but allows similar
countries to set their taxes to maximize joint welfare. Previous work
has not examined actual tax cooperation. (14) We show that, even when
tax rates are cooperatively set by countries that are symmetric, welfare
with tax harmonization may fall below welfare with tax competition.
Section II presents the building blocks of our framework. In
Section III, we solve a simple model that captures the essence of our
results. In Section IV, we move beyond the specific functional forms
used in Section III to generalize our results and formalize them in
propositions. In Section V, we discuss the welfare effects of tax
harmonization when countries are symmetric. Section VI considers a
number of extensions of our model such as asymmetric countries, an
alternative move order, more than two jurisdictions, and a discussion of
the effect of minimum tax rates as an alternative form of tax
harmonization. Section VII presents the conclusion.
II. THE MODEL SETUP
Consider two jurisdictions, "Home" and
"Foreign" (denoted by H and F, respectively), which are both
prospective host locations for multinational firms from other countries.
The jurisdictions can be different countries or different regions of the
same country with independent tax raising authority as well as public
infrastructure decision making power, but throughout the model we will
refer to these jurisdictions as "countries." The two countries
compete for third-country FDI as this generates benefits for each. One
obvious benefit is the tax revenue that the government collects from
multinationals. Naturally, these tax revenues increase in the actual
amount of FDI attracted into the country. One way to increase the amount
of FDI a country attracts is to lower its corporate tax rate, which in
turn will raise the country's tax base. An increase in public
infrastructure investment also increases the amount of FDI a country
attracts, and, in addition, it raises the profits of the multinational
plants that had already decided to locate in the country involved. Both
effects of public infrastructure work toward increasing the
country's tax base.
Tax revenues from multinationals located in H are represented by
t[B.sub.t] where t [member of] [0, 1] is H's profit tax rate and B
denotes the aggregate pretax profits of multinational firms located in
H. For brevity, we will refer to B as H's (multinational) tax base
and B* as F's (multinational) tax base. These mobile tax base
functions can be written as:
(1a) B = B(t,t*,x, x*),
and
(1b) B* = B* (t,t*,x,x*).
We assume B = 0 at t = 1 and B* = 0 if t* = 1. Also, we assume
[B.sub.t] < 0, where subscripts here and elsewhere denote partial
derivatives. This captures the idea that a higher tax rate reduces the
tax base as it reduces the inward FDI into H. We have [mathematical
expression not reproducible] > 0 because the countries are substitute
locations for multinational investment. The partial derivatives of B*
are analogous. Local infrastructure can be expected to both make a
location more attractive for multinational investment and to raise the
profitability at that location. Since both of these effects work toward
raising the aggregate pretax profits of multinationals in the region
that invests in public infrastructure, [B.sub.x] > 0 and [B*.sub.x*]
> 0. Signing the cross effects, [B.sub.x*] and [B*.sub.x], is less
straightforward as these depend on whether the externality that one
country's public infrastructure investment generates for the other
is negative or positive. A rival host country's investment in
public infrastructure may reduce a country's relative
attractiveness to multinationals and therefore its multinational tax
base. This could, for instance, be the case when the rival host location
invests in education. However, some types of public infrastructure
investment could be beneficial to countries other than the investing
country itself. For example, a country's investment in a major
local port may increase the attractiveness of other nearby prospective
host countries as well. In that case, the investment in public
infrastructure by one country entails a positive cross-border
externality to the nearby country. We define the ratios
[lambda](t,t*,x,x*) [equivalent to] [B*.sub.x]/[B.sub.x] and [lambda]*
(t, t*,x,x*) [equivalent to] [B.sub.x*]/[B*.sub.x*]; [lambda]>0
implies that the externality is positive ([B*.sub.x] > 0), while
[lambda] < 0 indicates the externality is negative ([B*.sub.x] <
0). (15) We assume -1 [less than or equal to] [lambda] [less than or
equal to] 1 and -1 [less than or equal to] [lambda] [less than or equal
to] 1, which implies that the effect of a country's infrastructural
investment is always at least as strong on the own country as its
effect--whether positive or negative--on the competing country.
Welfare for H and F, respectively, is given by:
(2a) W(t,t*,x,x*) = tB(t,t*,x,x*) - [OMEGA](x)
and
(2b) W* (t,t*,x,x*) = t*B* (t,t*,x,x*)-[OMEGA]* (x*)
where [OMEGA](x) and [OMEGA]*(x*) stand for the costs of
infrastructural investment in H and F, respectively. We assume that
these are increasing convex functions of public infrastructure
([OMEGA]" (x) > 0 and [OMEGA]*"(x*)>0).
In addition to improving the local business environment for inward
FDI, public infrastructure clearly has many direct social and economic
benefits. Furthermore, FDI, apart from generating tax revenue, can also
provide many other benefits, and in some cases costs, to a country. For
instance, it can affect the activity of domestic firms. We do not
include taxes from domestic firms in t[B.sub.t] because, although they
contribute to the general tax base, they do not contribute to the
multinational tax base. (16) However, there might be other good reasons
to include the activity of domestic firms in the welfare function. (17)
The effect of FDI on domestic firms could vary in sign depending on
whether foreign firms benefit or hurt domestic firm activity. Thus, an
increase in FDI could stimulate some domestic firms (for instance,
inward FDI may generate technological spillovers to some domestic
firms), while crowding out others. (18) Furthermore, there may be
beneficial interaction effects between public infrastructure and FDI;
for instance, a more developed public infrastructure may allow a country
to benefit to a greater extent from any spillovers from inward FDI. (19)
To take account of the effects on domestic business activity and
other social effects, we will introduce an "additional benefit
function" that captures all of the economic and social effects of
public infrastructure and FDI that are not included in the revenue from
the taxation of multinationals (tB and t*B*). We will represent these
additional benefits to Home and Foreign by g and g*, respectively, and
assume that g(x, t, k) is increasing in Home infrastructure, x, and
decreasing in t as higher taxes would reduce domestic firm activity.
Inward FDI, denoted by k, could have overall positive or negative
effects on g as discussed above. Inward FDI is decreasing in t and
increasing in t* and x. The volume of FDI may also depend on x*, though
the sign is ambiguous. Taking all these effects into account, we can
write the nontax benefits of inward FDI and public infrastructure in
compact form as G(t, t*, x, x*) = g[k(t, t*, x, x*), x,. t] and G*(t,
t*, x, x*) = g*[k(t, t*, x, x*), x*, t*] for Home and Foreign,
respectively. Including these benefits into expressions (2a) and (2b)
gives us the enhanced welfare functions for the respective countries.
The sign of the partial derivatives of G(t, t*, x, x*) will be affected
by that of [g.sub.k]. In the case in which this is positive, implying
that an increase in FDI has positive additional benefits on the domestic
country, we get [G.sub.t] < 0, [G.sub.t*] > 0, [G.sub.x] > 0,
and [G.sub.x*] ambiguous. If [g.sub.k] is negative, due perhaps to the
crowding out of domestic firms, then some of these signs could be
reversed (we will return to this in subsection IV.A). The partial
derivatives of G*(t, t*, x, x*) are analogous. Throughout our analysis,
we will use the welfare functions in expressions (2a) and (2b), but will
point out briefly when and how our qualitative results would change if
the enhanced welfare expressions were used.
We will consider two two-stage games. In one game, jurisdictions
choose taxes noncooperatively; in the other, they set tax rates
cooperatively. In the first stage of each game, governments
simultaneously choose investment levels in public infrastructure and
subsequently, in the second stage, they set corporate tax rates. We
solve each game by backward induction. The move order is based on the
fact that infrastructure investment typically has more commitment value
than taxes as it involves a long-run decision and is to a large extent
irreversible. (20)
We first solve a specific case of our model, in which we use a
linear function for each region's multinational tax base and a
quadratic function for the regional cost of public infrastructure
investment. The use of these special functional forms allows us to side
step the technicalities involved in solving the general model and thus
present our results in as transparent a way as possible. We will refer
to this case as the "linear-quadratic" (LQ) case.
Subsequently, we generalize the model and formulate our results in
propositions.
III. THE LINEAR-QUADRATIC CASE
In the LQ case, the multinational tax bases in H and F are,
respectively, given by:
(3a) B = [alpha]-[beta](t-[epsilon]t*) + [gamma] (x + [lambda]x*)
and
(3b) B* = [alpha] - [beta] (t* - [epsilon]t) + [gamma] (x* +
[lambda]x).
In expressions (3a) and (3b), [alpha], [beta], and [gamma] are
positive, 0 < [epsilon] < 1 and -1 [less than or equal to]
[lambda] [less than or equal to] 1, so that the sign of the partial
derivatives of B and B* are as discussed in the previous section. (21)
The respective public infrastructure investment cost functions for H and
F are, respectively, given by [OMEGA](x) = ([omega]/2)[x.sup.2] and
[OMEGA]*(x*) = ([omega]/2)[x*2], with [omega] > 0. As indicated by
our expressions, we assume for now that the two countries are completely
symmetric. We examine the effect of asymmetry between the countries in
Section VI.
A. Tax Competition
First consider the game in which taxes are set noncooperatively.
Stage 2: Noncooperative Tax Setting. The governments simultaneously
and noncooperatively choose taxes given infrastructural investment
levels x and x*. The Home government maximizes Home welfare with respect
to t, which yields its tax reaction function, t = [psi](t* ;x, x*):
(4) t = [psi] (t*;x,x*) = ([alpha] +[gamma] (x + [lambda]x*))
/2[beta] + ([epsilon]/2)t*.
The tax reaction function for the Foreign government is analogous.
From expression (4), we can see that taxes are strategic complements.
The tax reaction functions shift outward in the country's own
public infrastructure investment and in the competing country's
public infrastructure investment if the latter generates a positive
externality.
The equilibrium tax rate for Home, denoted by [t.sup.N], is:
(5) [t.sup.N] = [(2 + [epsilon])[alpha]]/[[beta]
(4-[[epsilon].sup.2])] + [gamma] [(2 + [epsilon][lambda])x + (2[lambda]
+ [epsilon])x*]/[[beta] (4 - [[epsilon].sup.2])] .
Given symmetry, the equilibrium tax rate in Foreign, [t*.sup.N],
takes the same form with the role of x and x* reversed.
Let us now examine how investment in public infrastructure affects
equilibrium tax rates. A country's tax rate is always increasing in
its own investment in public infrastructure (d[t.sup.N]/dx > 0 from
expression (5)). The effect of a country's investment in public
infrastructure on the other host country's corporate tax rate
(d[t.sup.N]/dx*) is ambiguous and depends on the externality on the
rival host country. When a country's infrastructure investment
generates a positive or not too negative externality for the rival host
country (i.e., [lambda]>[bar.[lambda]] [equivalent to] -[epsilon]/2),
it raises the latter's tax rate, but the opposite is true when the
externality is negative and sufficiently strong (i.e.,
[lambda]>[bar.[lambda]] [equivalent to] -[epsilon]/2).
Stage 1: Investment in Public Infrastructure under Tax Competition.
We now determine each country's optimal investment level in
infrastructure. For ease of exposition, we focus on H's choice.
F's choice of investment is completely analogous. Home maximizes
welfare with respect to x, taking [t.sup.N] = [t.sup.N](x, x*) (see
expression (5)) and [t*N] = [t*N](x, x*) into account. This yields the
first-order condition for x:
(6) dW/dx = [W.sub.x] + [W.sub.t] (d[t.sup.N]/dx) + [W.sub.t*]
(d[t*N]/dx) = 0.
Using the envelope theorem, [W.sub.t] = 0 from the second stage.
When discussing expression (6), it proves helpful to use the
"strategic investment" terminology pioneered by Fudenberg and
Tirole (1984). The first term in expression (6) is the direct effect of
x on Home welfare, with [W.sub.x] = t[gamma] - [omega]x. Let us focus on
this term first. If governments were to choose public infrastructure
investment simultaneously to setting taxes, H would choose x such that
[W.sub.x] = 0, implying that the marginal direct benefits of public
infrastructure investment would be equal to its marginal costs (i.e.,
t[gamma] = [omega]x). We will henceforth refer to this hypothetical
case, in which [W.sub.x] = 0, as the "nonstrategic
simultaneous-move benchmark." The last term in expression (6) is
the "strategic" term ([W.sub.t], (d[t*N]/dx)). The sign of
this term determines whether the Home government will--in the
terminology of Fudenberg and Tirole (1984)--"over-" or
"under" invest, relative to the hypothetical nonstrategic
benchmark, in order to manipulate the tax rates set in the rival
jurisdiction. If the strategic term is positive, then the first term in
expression (6) has to be negative ([W.sub.x] < 0) and we say that the
Home government "over" invests in public infrastructure
relative to the nonstrategic benchmark. It is important to stress that
by overinvestment, we certainly do not mean unproductive investment. In
our model, all the infrastructural investment is productive in raising
the multinational tax base. Investment in infrastructure raises the tax
base directly; in some circumstances it raises the other
jurisdiction's optimal tax rate. When it does, the marginal benefit
of infrastructural investment is increased and the optimal level is
higher than it would be in the nonstrategic simultaneous-move benchmark.
If the strategic term is negative, then the opposite holds ([W.sub.x]
> 0) and the government "under" invests relative to the
nonstrategic benchmark.
To determine which of these cases will occur, we need to examine
the strategic term in detail. The term can be decomposed into [W.sub.t*]
and d[t*N]/dx. We have [W.sub.t*] = t[beta][epsilon] > 0, implying
that the Foreign tax rate is "friendly," which means that a
rise in Foreign's tax rate increases Home welfare. (22) The sign of
the strategic term therefore depends on the sign of d[t*N]/dx, which, as
shown earlier, depends on the sign of 2[lambda] + [epsilon]. So, if
[lambda] is above the threshold [bar.[lambda]] = -[epsilon]/2 (hence,
d[t*N]/dx > 0), then Home will "over" invest in public
infrastructure ([W.sub.t*] (d[t*N]/dx) > 0, hence [W.sub.x] <0).
However, when [lambda] < [bar.[lambda]] = -[epsilon]/2, it will
"under" invest ([W.sub.t*] (d[t*N]/dx) < 0, hence [W.sub.x]
> 0).
Intuitively, governments wish to avoid a race to the bottom in
corporate tax rates and will act strategically when choosing their
investment levels in public infrastructure. When a country's
investment in public infrastructure raises the rival host country's
tax rate, it will choose to increase its investment, as a high tax rate
in the rival host country will allow the investing country to set a high
tax rate itself. When its investment does the opposite, the investing
country will avoid low tax rates by limiting its investment in public
infrastructure.
The equilibrium level of public infrastructure investment in H is:
(7) [x.sup.N] =[2[eta][alpha](2 + [epsilon][lamdba])]/[D.sup.N]
with [D.sup.N] [equivalent to] [gamma][[beta](2 - [epsilon])(4 -
[[epsilon].sup.2]) - 2[eta](1 + [lambda])(2 + [epsilon][lambda])] >
0, where [eta] [equivalent to] [[gamma].sup.2] /[omega] is a measure of
the relative effectiveness of public infrastructure investment.
B. Tax Cooperation
Here, we continue to assume that countries choosing their public
infrastructure investment levels, x and x*, in stage 1, do so
independently. However, the tax rate, set in stage 2, is now common. We
will assume that the governments can set the harmonized tax at the
jointly optimal level given the infrastructure levels set in stage 1. We
have chosen to model tax harmonization as tax cooperation as it would be
expected to be more favorable than any other forms of tax harmonization.
Our analysis thus provides us with a first rule of thumb for assessing
the success of tax harmonization initiatives: if the conditions are such
that even actual tax cooperation reduces welfare of the countries
involved, the prospects for finding a simple welfare improving form of
tax harmonization would seem very remote. (23)
Using expression (3a) and setting t = t* = [tau], the expression
for the multinational tax base in Home is now given by:
(8) B = [alpha] - [beta](1-[epsilon])[tau] + [gamma](x +
[lambda]x*).
The common tax rate is chosen to maximize the sum of Home and
Foreign welfare, W + W*, taking account of the fact that, at this stage,
public infrastructure has already been chosen. The first-order condition
for the jointly optimal tax rate is:
(9) [W.sub.[tau]] + [W*.sub.[tau]] =
[tau]([B.sub.[tau]]+[B*.sub.[tau]]) +B + B* =0,
implying that the common tax rate under tax cooperation is given
by:
(10) [[tau].sup.C] = 2[alpha] + [gamma](1+[lambda])(x +
x*)/4[beta](1-[epsilon]).
Investment in public infrastructure in either country (weakly)
raises the common tax rate (d[[tau].sup.C]/dx = d[[tau].sup.C]/dx* =
[gamma](1 + [lambda])/[4[beta](1 - [epsilon])] [greater than or equal
to] 0) (24).
In stage 1, Home and Foreign choose their public infrastructure
investment levels noncooperatively, taking account of the effect on the
future cooperatively set corporate tax. The first-order condition for
Home welfare maximization with respect to infrastructural investment is:
(11) [W.sub.x] + [W.sub.[tau]](d[[tau].sup.C]/dx)=0
with [W.sub.x] = [gamma][tau]- [omega]x and [W.sub.[tau]] = B -
[beta](1 - [epsilon])[tau]. The first-order condition for Foreign
welfare maximization is similar. As d[[tau].sup.C]/dx =
d[[tau].sup.C]/dx* > 0, the sign of the strategic term in expression
(11) depends on the friendliness term, Wr. As expression (9) can, given
symmetry, be rewritten as [W.sub.[tau]] + [W*.sub.[tau]] =
2[W.sub.[tau]] = 0, it implies [W.sub.[tau]] = 0. This means that the
strategic term in expressions (11) vanishes and hence neither country
invests strategically. As expression (11) reduces to [W.sub.x] = 0 and
with [[tau].sup.C] given by expression (10), optimal public
infrastructure investment levels under tax cooperation (denoted by
[x.sup.C] and [x*C]), are then given by:
(12) [x.sup.C] = [x*C] = [eta][alpha]/[D.sup.C]
with [D.sup.C] = [gamma][2[beta](1 - [epsilon]) - [eta](1 +
[lambda])] > 0 to guarantee stability.
In Figure 1 we depict the first-order conditions for infrastructure
and taxes in symmetric (x,t)space; these are drawn for tax competition
([x.sup.N] (t) and [t.sup.N](x)) and for tax cooperation
([x.sup.C]([tau]) and [[tau].sup.C](x)). In both Figures 1A and
[B.sub.t] the equilibrium under tax competition is indicated by point N
and the equilibrium under tax cooperation by point C. Figure 1A
illustrates the two equilibria for [lambda] > [bar.[lambda]], while
Figure 1B does so when [lambda] < [bar.[lambda]].
Before discussing the welfare effects of tax cooperation, we will
generalize the model in the next section and formulate our results in
propositions.
IV. THE GENERAL MODEL
In this section, we generalize our results obtained for the LQ
case. For this purpose, we use the general function forms specified in
Section II and unless otherwise stated we do not impose symmetry. The
purpose of this section is to explore the robustness of our model. With
linear functional forms taxes are strategic complements and the
threshold level of externality below which countries strategically
underinvest in infrastructure to reduce the rival's taxes is
negative. We extend the analysis by allowing for the possibility that
taxes could be strategic substitutes rather than complements and study
how this affects the critical threshold. We show that the sign of the
threshold depends on whether taxes are strategic substitutes or
complements.
A. Tax Competition
Again, we first consider the game in which taxes are set
noncooperatively.
Stage 2: Noncooperative Tax Setting. In stage 2, governments
simultaneously and noncooperatively choose taxes, given infrastructural
investment levels x and x*, to maximize expressions (2a) and (2b).
First-order conditions associated with welfare maximization,
[W.sub.t](t, t*,x, x*) = 0 for H and [W*.subn.t*] (t*, t,x*,x) = 0 for
F, yield H's and F's tax reaction functions, given by t =
[PSI](t* ;x, x*) and t* = [PSI] (t;x, x*), respectively.
Let us now examine the properties of these reaction functions. The
slope of H's tax best response functions is given by [[PSI].sub.t*]
= -[W.sub.tt*]/[W.sub.tt]. As the second-order conditions require Wlt
< 0, the sign of [[PSI].sub.t*] is the same as that of [W.sub.tt*],
with [W.sub.tt*] = [B.sub.t*] + t[B.sub.tt*]. The term [B.sub.t*] is
positive and so works toward [W.sub.tt*] and [[PSI].sub.t*] being
positive. The intuition is that an increase in the tax in F makes H a
relatively attractive location and, since this increases Home's tax
base, it works toward raising the marginal benefit of the tax. The sign
of t[B.sub.tt*] is ambiguous. However, provided that this term is not
too negative, the tax best-response functions are positively sloped and
corporate tax rates are strategic complements. One can think of this as
the "normal case," which is guaranteed in the LQ case but not
in general. The following assumption ensures that the cross effects,
[W.sub.tt*] and [W*.sub.t*t], do not dominate the direct effects,
[W.sub.tt] and [W*.sub.t*t], and guarantees the stability of the tax
game:
ASSUMPTION 1. [absolute value of [W.sub.tt]] > [absolute value
of [W.sub.tt*]] and [absolute value of [W*.sub.t*t*]] >[absolute
value of [W*.sub.t*t]].
We now examine the impact of investment in public infrastructure on
the reaction functions. Investment in public infrastructure causes them
to shift. The impact on H's reaction function is captured by
[[PSI].sub.x] = -[W.sub.tx]/[W.sub.tt] and, similarly, by [[PSI].sub.x*]
= -[W.sub.tx*]/[W.sub.tt]. As we have [W.sub.t] = B + t[B.sub.t] = 0,
and hence t = -B/[B.sub.t], we can rewrite [W.sub.tx] = [B.sub.x] +
t[B.sub.tx] as [W.sub.tx] = [B.sub.x] - [B.sub.tx] (B/[B.sub.t]).
Similarly, we can rewrite [W.sub.tx*] = [B.sub.x*] + t[B.sub.tx*] as
[B.sub.x*] - [B.sub.tx*] (B/[B.sub.t]). Defining R [equivalent to] 1 -
(B/[B.sub.t])([B.sub.tx]/[B.sub.x]) and r [equivalent to] 1 -
(B/[B.sub.t]) ([B.sub.tx*]/[B.sub.x*]), we can write [W.sub.tx] =
R[B.sub.x] and [W.sub.tx*] = r[B.sub.x*]. Let R and r* be analogously
defined for the Foreign jurisdiction. We will assume that the following
reasonable restriction holds:
ASSUMPTION 2. R > 0, r > 0, R* > 0 and r* > 0.
This condition is guaranteed to hold in many special cases
including the LQ case discussed in the previous section. R>0 implies
that the tax elasticity of the region's multinational tax base
(-[B.sub.t](t/B)) is decreasing in public infrastructure investment.
(25) The idea here is that inflows of FDI become less sensitive to
corporate taxes when the region is more attractive because of higher
infrastructural provision. Likewise, r > 0 implies that, if F's
investment makes H's location less attractive on infrastructural
grounds, then H's multinational tax base becomes more sensitive to
taxes. (26) From Assumption 2, [[PSI].sub.x] > 0. The sign of
[[PSI].sub.x*], which captures the cross effect of Foreign's public
infrastructure on Home's tax reaction function, depends on that of
[B.sub.x*] and is therefore ambiguous. We assume that the absolute
impact of own investment on the own tax reaction function is at least as
large as its impact on the rival reaction function, or:
ASSUMPTION 3. [absolute value of [[PSI].sub.x]] [greater than or
equal to] [absolute value of [[PSI]*.sub.x]] and [absolute value of
[[PSI]*.sub.x*]] [greater than or equal to] [absolute value of
[[PSI].sub.x*]].
Note that all of the above Assumptions hold automatically in the LQ
version of the model.
Equilibrium tax rates--obtained by solving the reaction
functions--depend on the levels of public infrastructure governments
invested in period one and can be written as [t.sup.N] = [t.sup.N](x,
x*) and [t*N] = [t*N](x, x*). We restrict attention to unique
equilibria:
ASSUMPTION 4. For given infrastructural investment levels, the tax
equilibrium {[t.sup.N](x, x*), [t*N](x, x*)} is unique.
To determine the effect of x on equilibrium tax rates, we totally
differentiate the first-order conditions for welfare maximization and
obtain:
(13a) d[t.sup.N]/dx = [W*.sub.t*x] [W.sub.tt*] -
[W*.sub.t*t*][W.sub.tx]/[DELTA]
and
(13b) d[t*N]/dx = [W.sub.tx][W*.sub.t*t] -
[W.sub.tt][W*.sub.t*x]/[DELTA]
with [DELTA] [equivalent to] [W.sub.tt] [W*.sub.t*t*] -
[W*.sub.t*t] [W.sup.tt.sub.*] > 0, which follows from Assumption 1.
PROPOSITION 1. Under noncooperative tax setting, an increase in
public infrastructure increases the optimal tax in the investing
country.
Proof. See Appendix.
Using the expressions for [W.sub.tx], [W.sub.tx*], [W*.sub.t*x*],
and [W*.sub.t*x] we can rewrite expression (13b) and the analogous
expression d[t.sup.N]/dx* as:
(14a) d[t*N]/dx = A([lambda]-[bar.[lambda]])
and
(14b) d[t.sup.N]/dx* = A* ([lambda]*-[bar.[lambda]]*)
with A [equivalent to] -r*[B.sub.x][W.sub.tt]/ [DELTA] > 0, A* =
-r[B*.sub.x*] [W*.sub,t*t*]/ [DELTA] > 0, [bar.[lambda]] =
([W*.sub.t*t]R)/([W.sub.tt]r*), and [bar.[lambda]* = ([W.sub.tt*]R*)/
([W*.sub.t*t*] r). This gives us the following result.
PROPOSITION 2. Under noncooperative tax setting, (a) an increase in
public infrastructure in Home increases (decreases) the optimal tax in
the Foreign country if [lambda] > [bar.[lambda]] ([lambda] <
[bar.[lambda]]); (b) an increase in public infrastructure in Foreign
increases (decreases) the optimal tax in Home if [lambda]* >
[bar.[lambda]]* ([lambda]* < [bar.[lambda]]*).
The critical externality levels, [bar.[lambda]] and
[bar.[lambda]]*, above which an increase in public infrastructure raises
the rival location's corporate tax, are negative when taxes are
strategic complements but positive when taxes are strategic substitutes.
To understand this intuitively, it is helpful to first examine the
special case in which Foreign's tax reaction function does not
shift when Home infrastructure changes (i.e., in the case that B* is
independent of x). Then, since an increase in Home infrastructure shifts
Home's tax reaction function to the right, it clearly raises the
Foreign tax if the Foreign reaction function is upward sloping
([W*.sub.t*t] > 0), but reduces the tax when the Foreign reaction
function slopes down ([W*.sub.t*t] < 0). Now, allow for the Foreign
reaction function to shift when Home infrastructure increases (i.e., in
the case that B* directly depends on x). When the cross-border
externality is positive, the Foreign reaction function shifts out,
working toward a higher Foreign tax. But, if the externality is
negative, the Foreign reaction function shifts in, which works toward a
reduction in the tax. So, for an increase in Home infrastructure not to
increase the Foreign tax when the Foreign reaction function is upward
sloping (i.e., [W*.sub.t*t] > 0) requires that the externality be
sufficiently negative; for it not to lead to a decrease in the Foreign
tax when the Foreign reaction function slopes down (i.e., [W*.sub.t*t]
< 0) requires that the externality be positive enough.
In Section II, we discussed the fact that FDI and public
infrastructure can provide many benefits in addition to tax revenue. We
used G(t, t*, x, x*) and G*(t, t*, x, x*) to capture these benefits. Let
us now briefly consider what difference the inclusion of G and G* in the
welfare functions makes.
First, with Home welfare written in its enhanced form as W = tB +
G- [OMEGA], the first-order condition for the Home tax is now t[B.sub.t]
+ B + [G.sub.t] = 0. Hence, the optimal tax can be written as t =
-(B/[B.sub.t])-([G.sub.t] /[B.sub.t]). We saw in Section II that, when
an increase in FDI has an overall positive effect on the domestic
economy, [G.sub.t] must be negative. A negative [G.sub.t] works toward a
lower tax. The intuition is straightforward. The government has
additional reasons to attract FDI and so has a stronger incentive to cut
the corporate tax rate. However, if there is a strong enough crowding
out effect of FDI on domestic firms and the activity of these firms
matters enough to the government, [G.sub.t] can change sign and become
positive. A positive [G.sub.t] works toward a higher corporate tax.
Second, there is a more subtle effect on the strategic incentive to
invest in public infrastructure. When additional benefits of FDI and
public infrastructure are taken into account, investment in
infrastructure could in some cases shift a country's tax reaction
function inward rather than outward. This would, however, only be the
case if [G.sub.tx] is sufficiently negative such that [W.sub.tx] =
[B.sub.x] + t[B.sub.tx] + [G.sub.tx]< 0 (Assumption 2 ensures
[B.sub.x] + t[B.sub.tx] > 0). So, when would [G.sub.tx] be negative?
Intuitively, this could occur when public infrastructure increases the
nontax benefit to the country of FDI. To see this, assume that [G.sub.t]
is negative. If infrastructure makes FDI even more useful to the
country, then x tends to make [G.sub.t] even more negative
([G.sub.tx]< 0). So, for instance, a country with a more developed
education system may have a greater capacity to absorb and make
productive use of spillovers from foreign multinationals. Such an
"absorptive capacity" effect thus works toward [G.sub.tx]
being negative. If [G.sub.tx] is sufficiently negative, then
[W.sub.tx]< 0 and [[PSI].sub.x] <0, thus working to reverse the
strategic incentive to invest in public infrastructure. For instance, if
taxes are strategic complements, an increase in Home's
infrastructure works toward a reduction in both taxes rather than an
increase.
In the remainder of the article, we return to the case in which G =
G* = 0.
Stage 1: Investment in Public Infrastructure under Tax Competition.
We now determine the countries' optimal investment in
infrastructure. For ease of exposition we will focus on H's choice.
F's choice of investment is completely analogous. The first-order
condition for Home welfare maximization is given by (6) with [W.sub.t] =
0 from the second stage. The first term in expression (6), the direct
effect of x on Home welfare, is equal to [W.sub.x] =
t[B.sub.x]-[OMEGA]'. The sign of the strategic term, the last term
in expression (6), determines whether the Home government will, in order
to manipulate the tax rates set in the rival host country, over- or
underinvest relative to the hypothetical nonstrategic benchmark. Recall
that this benchmark was earlier defined in Section III as the case in
which governments choose public infrastructure and tax rates at the same
time, implying that first-order conditions for x and x* reduce to
[W.sub.x] = 0 and [W*.sub.x*] = 0.
PROPOSITION 3. Under noncooperative tax setting, the Home
government will (a) strategically overinvest in public infrastructure
relative to the nonstrategic benchmark if dt*/dx>0; (b) strategically
underinvest in public infrastructure relative to the nonstrategic
benchmark if dt*/dx < 0.
Proof. To determine which of these cases will occur, we need to
examine the strategic term in detail. The term can be decomposed into
[W.sub.t*], and dt*/dx. We have [W.sub.t*] = t[B.sub.t*] > 0,
implying that the Foreign tax rate is "friendly," which means
that a rise in Foreign's tax rate increases Home welfare. The sign
of the strategic term therefore depends on the sign of dt*/dx.
B. Tax Cooperation
In this subsection, we restrict attention to symmetric countries.
ASSUMPTION 5. The countries are identical: they have symmetric tax
base functions and identical public infrastructure cost functions.
This assumption will facilitate a comparison with the first best,
which we will discuss in the next section. The first-order condition for
the jointly optimal tax is given by expression (9), with [W.sub.[tau]] =
[W*.sub.[tau]] in a symmetric equilibrium and so 2[W.sub.[tau]] = 0
(from expression (9)), implying [W.sub.[tau]] = 0. To compare the
harmonized and nonharmonized taxes, note that [W.sub.[tau]] = 0 can be
written as [W.sub.t] + [W.sub.t*] = 0. As [W.sub.t*] > 0, this
implies [W.sub.t] < 0, meaning that, at given (symmetric) public
infrastructure investment levels, the cooperative taxes are higher than
those under noncooperation.
In stage 1, the Home country chooses its public infrastructural
investment noncooperatively, for which the first-order condition is
given by expression (11). As the equilibrium in public infrastructure is
symmetric, [W.sub.[tau]] + [W*.sub.[tau]] = 2[W.sub.[tau]] = 0. In turn,
this implies [W.sub.x] = 0 (from expression (11)) and, as discussed in
the previous section, this means that investment is set according to the
nonstrategic simultaneous-move benchmark.
PROPOSITION 4. When countries are symmetric, tax cooperation
eliminates strategic investment in public infrastructure.
Thus, our findings in the LQ-case for tax cooperation continue to
hold with general functional forms.
V. TAX COMPETITION VERSUS TAX COOPERATION: A WELFARE COMPARISON
In this section, we compare welfare levels under tax competition
and tax cooperation. It is a priori not certain that cooperative tax
setting alone will yield higher welfare levels than tax competition
since, even under tax cooperation, countries set their infrastructure
independently. First, we show that tax cooperation typically does not
yield the "first-best" outcome. Second, we determine the
conditions under which tax competition actually yields an outcome that
is welfare superior to the outcome under tax cooperation.
A. The First Best
The first-best outcome is reached when a social planner, maximizing
joint welfare of Home and Foreign, decides on the tax rate and each
country's investment in public infrastructure. This outcome is
replicated by the countries jointly setting both the tax rate and public
infrastructure levels to maximize their joint welfare, that is, when the
countries cooperate on public infrastructure and taxes. Assuming that
the optimization problem has a unique interior solution, the first-order
condition for the first-best tax is given by expression (9), whereas the
optimal choice of infrastructure is given by:
(15) [W.sub.x] + [W*.sub.x] = 0
where [W.sub.x] = [tau][B.sub.x] - [OMEGA]' and [W*.sub.x] =
[tau][B*.sub.x]. The following proposition does not rely on special
functional forms.
PROPOSITION 5. With symmetric countries the cooperative tax outcome
coincides with the first-best joint optimum only when [lambda] = 0.
Proof. At [lambda] = 0, [W*.sub.x] =0, which implies that
expression (15) is reduced to [W.sub.x] = 0. In addition, the
first-order condition for the first-best tax is given by expression (9).
Hence, at [lambda] = 0, both first-order conditions for the first best
are identical to those for the case with tax cooperation alone.
At the first best, unlike at the cooperative harmonized tax
equilibrium, each country's public infrastructural investment is
chosen taking full account of the external effect on the other
country's welfare. Hence, tax cooperation alone will not yield the
first-best outcome when public infrastructure investment generates
cross-border externalities. To attain the first best when there are
cross-border positive or negative externalities would require the
countries to not just cooperate on taxes but to cooperate on public
infrastructure as well. (27)
B. Tax Competition Versus Tax Cooperation
We now show that the tax cooperation may even yield a lower welfare
level than tax competition when one country's public infrastructure
investment generates externalities for the other host country. Since a
welfare comparison between tax cooperation and tax competition requires
specific functional forms, we use the LQ version of our model.
In Figures 2A-C, we again depict the firstorder conditions for
infrastructure and taxes in symmetric (x,t)-space; these are now not
only shown for tax competition ([x.sup.N](t) and [t.sup.N](x)) and for
tax cooperation ([x.sup.C](x) and [[tau].sup.C](x)), but also for the
first best ([x.sup.O](x) and [[tau].sup.O](x)), where the first-best
outcome is represented by point O. In Figure 2A, there is no externality
from public infrastructure investment ([lambda] = 0). In that case, as
shown by Proposition 5, tax cooperation actually yields the first-best
outcome and hence the first-best welfare level, whereas tax competition
clearly attains a lower welfare level (represented by the fact that it
lies on the [W.sup.N]-isowelfare contour, with [W.sup.N] <
[W.sup.O]). When there is an externality, positive or negative, welfare
under tax cooperation always falls below the first-best welfare level.
Nevertheless, for positive externalities ([lambda] > 0), tax
cooperation always yields a higher welfare level than tax competition,
which is illustrated in Figure 2B ([W.sup.C] > [W.sup.N]). However,
this is not always the case when the externality is negative
([lambda]<0). Why is this so? With tax cooperation equilibrium tax
rates are higher than with tax competition. This implies that levels of
public infrastructure investment are higher with tax cooperation than
with competition. However, with each country investing in public
infrastructure that is harmful to the other host country, the
externality will lower welfare in each country. Furthermore, when
investment in public infrastructure is relatively effective (i.e., when
r|, defined earlier as [[gamma].sup.2]/[omega], is high), investment
under tax cooperation will be a lot higher than with tax competition,
thereby magnifying the negative welfare effect of public infrastructure
investment on each country.
In the LQ case under tax competition, the first-order condition for
welfare maximization [W.sub.t] = B + t[B.sub.t]= 0 implies B =
-t[B.sub.t] = [beta][t.sup.N]. Also, since [W.sub.x] = t[gamma]-
[omega]x, [W.sub.t*] = t[beta][epsilon], and dt*/dx = (2[lambda] +
[epsilon])[gamma]/[[beta](4 - [[epsilon].sup.2])] in expression (6), we
can write [x.sup.N] = ([eta]/[gamma]) [1 +2[epsilon] (([lambda] -
[bar.[lambda]])/(4-[[epsilon].sup.2]))] [t.sup.N]. Hence each
region's welfare level under tax competition is given by:
(16) [W.sup.N] = [beta][1 - [eta]/2[beta][(1 +2[epsilon] ([lambda]
-[bar.[lambda]])/4-[[epsilon.sup.2]).sup.2]] [([t.sup.N]).sup.2] = [W*N]
with [t.sup.N] = [t*N] =
[alpha]/[beta](2-[epsilon])-[eta](1+[lambda])(1+2[epsilon][lambda]-[bar.[lambda]]/ 4-[[epsilon].sup.2]).
With tax cooperation and symmetric countries, expression (9)
implies 2[W.sub.[tau]] = 0, hence B = -[tau] [B.sub.x] = [beta](1 -
[epsilon])[tau]. Furthermore, [W.sub.x] = [tau][gamma] - [omega]x and
d[tau]/dx = (1 +[lambda])[gamma]/[4[beta](1 -[epsilon])] from expression
(10). Hence, welfare in each jurisdiction under tax cooperation is equal
to:
(17) [W.sup.C] = [beta] [(1 - [epsilon]) - ([eta]/2[beta])]
[[tau].sup.2] = [W*C]
with [tau] = [alpha]/[2[beta](1 -[epsilon])-[eta](1 + [lambda])].
Even in the LQ case, the welfare expressions (expressions (16) and
(17)) are not easy to compare. It is helpful to illustrate the welfare
comparison diagrammatically. We use two figures to do this. Figure 3A
depicts welfare under tax competition and tax cooperation (as well as in
the first best) as functions of [lambda]. In the diagram, when [lambda]
is sufficiently negative, welfare under tax competition is higher than
under tax cooperation. Obviously, this diagram is drawn for specific
parameter values. While it is true that when externalities from public
infrastructure are positive, tax cooperation always yields higher
welfare than tax competition, tax cooperation does not necessarily give
lower welfare than tax competition when externalities are negative. In
fact, it is also necessary that, at the same time as the externality
being negative, the relative effectiveness of public infrastructure
([eta]) is high. Figure 3B demonstrates this by showing welfare under
the three regimes (tax competition, tax cooperation, and the first best)
as a function of [eta]; note that in this figure [lambda] < 0). At
the threshold [??], welfare under tax competition and cooperation are
equal. For low levels of [eta] ([eta] < [??]), tax cooperation
generates higher welfare than tax competition. However, for [eta]-levels
beyond [??] ([eta] > [??]), the welfare level attained under tax
competition is higher than under tax cooperation.
PROPOSITION 6. In the LQ-case, there exists a critical
[eta]-threshold, [??]([lambda]), with (i) [W.sup.C] ([??]) = [W.sup.N]
([??]) and (ii) d[??]/d[lambda] > 0.
Proof. See Appendix.
VI. EXTENSIONS
This section briefly discusses some extensions of the model. (28)
In the respective subsections, we address what happens if the countries
that are contemplating tax harmonization were asymmetric, we discuss the
outcomes of the game if taxes were chosen prior to infrastructure, we
extend our results to a setup with more than two jurisdictions, and
finally discuss what would happen under an alternative form of tax
harmonization.
A. Asymmetric Countries
So far, we assumed the countries involved are symmetric. In this
subsection, we discuss the effects of tax cooperation when countries are
asymmetric. (29)
We introduce country asymmetry in the most straightforward way,
that is, by assuming that one of the countries, Home, has, ceteris
paribus, a higher multinational tax base than Foreign, which is captured
in the LQ version of the model by introducing a parameter [alpha]* in
the tax base function for Foreign, with [alpha]* < [alpha]. This
could be because Home has an underlying advantage in attracting FDI.
Henceforth, we will refer to the "naturally more attractive"
country as Home for short. In the equilibrium with tax competition, Home
will now charge a higher tax rate than Foreign, while also investing
more in public infrastructure. When the countries cooperate and set a
common tax rate, [tau], the common (harmonized) tax rate is chosen to
maximize the sum of Home and Foreign welfare, W +W*. Welfare is always
higher in Home, that is, the country that is "naturally more
attractive" for FDI; so, [W.sup.N] > [W*N] and [W.sup.C] >
[W*C]. As in the case with symmetric countries, whether a country gains
or loses from tax cooperation depends on the relative effectiveness of
public infrastructure investment and on the level of the externality.
When the externality parameter is high, both countries gain from tax
cooperation and will agree to harmonize taxes. However, when the
externality is sufficiently negative, tax cooperation harms both
countries and there will be no incentive to set taxes cooperatively. For
intermediate externality levels, the "naturally more
attractive" country (Hom[epsilon]) prefers tax cooperation to tax
competition, while the opposite is true for the "naturally less
attractive" country. This result suggests that a peripheral, less
developed country may be less favorably disposed toward tax
harmonization than a core, highly developed country that is more
naturally attractive to FDI. In that case, countries may wish to bargain
over side-payments to sustain tax cooperation.
B. Reversing the Move Order: Taxes before Infrastructure
As we explained earlier, infrastructure is chosen before taxes in
our model because it is seen as having more commitment value than taxes:
it involves a long-run decision and is to a large extent irreversible.
However, it is worth briefly discussing what would happen in the
alternative case in which the sequence of decisions regarding
infrastructure and taxes is reversed.
If the sequence of decisions were reversed, infrastructure would be
chosen in stage 2, taking the taxes as given. Clearly, there would no
longer be scope to use infrastructure to strategically influence the tax
rates of the other jurisdiction. Home's stage 2 first-order
condition for infrastructure would be given by [W.sub.x] = 0. In stage
1, taxes would be chosen taking account of any effects that they would
have on the future infrastructural choice. In general, governments could
use taxes to strategically manipulate their rivals' infrastructure.
This effect cannot be definitely signed in general, but it is zero in
the linear case. So, in the linear case, the noncooperative outcome
differs from that in our model in which infrastructure is chosen before
tax rates, because of the absence of a strategic motive for
infrastructure, whereas the outcome under cooperation is identical to
that in our model.
C. Many Jurisdictions
So far, we have restricted attention to the case of two
jurisdictions. With n countries, Equation (3a) and (3b) can be replaced
by:
(18) [B.sub.i] = [alpha] - [beta] ([t.sub.i] - [epsilon][T.sub.-i])
+ [gamma] ([x.sub.i] + [lambda][X.sub.-i])
where [B.sub.i] is a typical country i's tax base, [t.sub.i]
is its tax rate, and [x.sub.i] is its infrastructure. Here, we write
[T.sub.-i] = [[SIGMA].sub.j[not equal to]i] [t.sub.j] and [X.sub.-i] =
[[SIGMA].sub.j[not equal to]i] [x.sub.j]. The welfare of country i can
be written as: [W.sub.i] =
[t.sub.i][B.sub.i]--([omega]/2)[x.sup.2.sub.i].
From this we can derive country i's secondstage noncooperative
equilibrium tax and the effect of a country's investment in public
infrastructure on another country's corporate tax rate
(d[t.sup.N.sub.j] /d[x.sub.i]):
(19) d[t.sup.N.sub.j]/ d[x.sub.i] = 2[lambda] + [epsilon]/[beta](2
+ [epsilon])(2 - (n - 1)[epsilon])
Expression (19) shows that, as in the two country case, the sign of
the strategic term continues to depend on whether [lambda] is greater or
smaller than the critical value, -[epsilon]/2. Although it is the case
that the strategic effect of infrastructure is stronger when each
country is playing against more rival jurisdictions, the addition of
more countries does not qualitatively affect this or the other results.
D. Harmonized Minimum Tax Rates
We now consider an alternative form of tax harmonization. Suppose
taxes are constrained not to fall below a minimum tax. Given this tax
floor, countries play a noncooperative two-stage game, setting
infrastructure in stage 1 and taxes in stage 2. When the minimum tax
rate is higher than [t.sup.N], the equilibrium tax rate in each region
is [[tau].sup.M]. There is then no longer any need to choose public
infrastructure investment levels strategically as the legally imposed
minimum tax rate effectively pushes the tax rates beyond the level that
would prevail when governments are unconstrained in choosing taxes. This
implies that one can expect a minimum tax, if effective, to increase
investment in public infrastructure when the latter generates a
sufficiently negative crossborder externality ([lambda] <
[bar.[lambda]], in which case there is an incentive to underinvest in
public infrastructure in the absence of a minimum tax). When public
infrastructure generates a cross-border externality that is above a
critical threshold level (i.e., [lambda] > [bar.[lambda]]), the
minimum tax rate eliminates the strategic incentive to overinvest in
public infrastructure, which works toward a lower level of
infrastructure. However, the tax floor now ensures a higher tax rate and
since the public infrastructure investment level is itself increasing in
the tax rate, there is a countervailing effect on the infrastructure
level that works toward increasing it. When the minimum tax is
sufficiently high, this second effect dominates and the infrastructure
is higher than in the non-cooperative case.
VII. CONCLUSION
A country's ability to attract inward FDI depends, among other
things, on corporate tax rates and on the level and quality of local
public infrastructure. Since a potential host country can attract more
FDI by increasing its investment in public infrastructure, the
multinational firm component of its tax base thus depends in part on the
level of local public infrastructure. Moreover, public infrastructural
investment in one country can also affect the attractiveness and hence
the multinational tax base of a competing host country, and may do so
either positively or negatively.
To study these issues, we have constructed a two-country model of
corporate tax competition for inward FDI, in which governments also
invest in public infrastructure. When the externality generated by one
country's investment in public infrastructure is above a critical
threshold level, governments strategically increase their investment in
infrastructure in order to raise the rival host country's corporate
tax rate. This softens tax competition and therefore benefits the
investing host country indirectly. However, if the externality is below
that critical threshold (for instance as a result of a strong business
stealing effect), then the strategic effect of public infrastructure is
negative and the investing country has an incentive to lower its public
infrastructure investment.
The external effect of public infrastructure on the other country
also affects the gains from tax harmonization. Although tax cooperation
can raise the welfare of countries, we have found that--even when
countries are symmetric--this is not always the case. In fact, when
infrastructure is sufficiently cost effective in enhancing a
country's attractiveness and hence in raising its own tax base
while generating a sufficiently large negative cross-border externality,
then tax cooperation, without infrastructure coordination, actually
reduces welfare. The reason for this lies in the fact that, although
resulting in higher equilibrium taxes and hence avoiding a race to the
bottom in tax rates, tax cooperation also leads to higher investment in
public infrastructure. When countries coordinate taxes but not
infrastructure, they ignore the business stealing negative externality
that their infrastructure imposes on other countries and they engage in
excessive (mutually damaging) investment. When this effect is strong
enough, tax cooperation results in lower welfare levels than tax
competition.
Our results are cautionary as they imply that policymakers may
inadvertently make matters worse by signing up to tax harmonization
programs without consideration of regional public infrastructure
investment schemes. Specifically, it provides policymakers of competing
jurisdictions who consider tax harmonization with a rule of thumb. If
tax cooperation, which is the form of tax harmonization that leads to
the highest welfare at given infrastructure levels when countries are
very similar, actually reduces welfare below the level attained with tax
competition, then alternative forms of tax harmonization cannot be
expected to raise welfare levels either. We found that, when rival host
jurisdictions experience very negative cross-border spillovers from each
other's public infrastructure investment projects, policymakers
should be most wary of any form of tax harmonization. By contrast, if
cross-border spillovers from public infrastructure investment are
positive, or negative but small, our model suggests that in those
circumstances tax harmonization is more likely to bear fruit.
APPENDIX
Proof of Proposition I. Under noncooperative tax setting, an
increase in public investment increases the optimal tax in the investing
country. Here, we will examine the case of the Home country.
From d[t.sup.N]/dx = [W*.sub.t*x][W.sub.tt*] -
[W*.sub.t*t*][W.sub.tx]/[DELTA], we know that the sign depends on that
of the numerator since [DELTA] > 0 from Assumption 1. To determine
the sign of the numerator, note that the derivative [W*.sub.t*t*] is
negative from the second-order condition for the foreign country and
[W.sub.tx] is positive from Assumption 2. So, it is the case that
-[W*.sub.t*t*] [W.sub.tx] > 0. This leads us to consider 4 cases:
Case (1): [W.sub.tt*] > 0 (taxes are strategic complements) and
[W*sub.t*x] [greater than or equal to] 0 (public infrastructure
generates a non-negative cross-border externality).
Case (2): [W.sub.tt*] < 0 (taxes are strategic substitutes) and
[W*.sub.t*x] [less than or equal to] 0 (public infrastructure generates
a nonpositive cross-border externality).
Case (3): [W.sub.tt*] > 0 (taxes are strategic complements) and
[W*.sub.t*x] [less than or equal to] 0 (public infrastructure generates
a nonpositive cross-border externality).
Case (4): [W.sub.tt*] < 0 (taxes are strategic substitutes) and
[W*.sub.t*x] [greater than or equal to] 0 (public infrastructure
generates a nonnegative cross-border externality).
It is clear that d[t.sup.N]/dx is guaranteed to be positive in
cases (1) and (2) above as then [W*.sub.t*x] [W.sub.tt*] [greater than
or equal to] 0, which reinforces -[W*.sup.t*t*] [W.sub.tx] > 0. It
remains to be shown that d[t.sup.N]/dx is also positive in cases (3) and
(4). In case (3), Assumption 3, which states [absolute value of
{[[PSI].sub.x]] [greater than or equal to] [absolute value of
[[PSI]*.sub.x], implies -[W.sub.tx]/[W.sub.tt] [greater than or equal
to] [W*.sub.t*x]/[W*.sub.t*t*] > 0 and so [W.sub.tx] [greater than or
equal to] -[W.sub.tt] ([W*.sub.t*x]/[W*.sub.t*t*]) >0. Hence, the
numerator -[W*.sub.t*x][W.sub.tx] + [W*.sub.t*x] [W.sub.tt*] is at least
as large as [W.sub.tt] ([W*.sub.t*x]/[W*.sub.t*t*]) [W*.sub.t*t*] +
[W*.sub.t*x][W.sub.tt*] = [W*.sub.t*x] ([W.sub.tt] + [W.sub.tt*]) > 0
since the term in brackets is negative from Assumption I. Hence, we
conclude d[t.sup.N]/dx = ([W*.sub.t*x],[W.sub.tt] - [W*.sub.t*t*]
[W.sub.tx]) /[DELTA] > 0. Next, consider case (4). Now, Assumption 3,
which states [absolute value of [[PSI].sub.x] [greater than or equal to]
[absolute value of [[PSI]*.sub.x]], implies -[W.sub.tx]/[W.sub.tt]
[greater than or equal to] -[W*.sub.t*x]/ [W*.sub.t*t*] > 0 and so
[W.sub.tx] [greater than or equal to] [W.sub.tt]([W*.sub.t*x]/
[W*.sub.t*t*])>0. Hence, the numerator -[W*.sub.t*t*][W.sub.tx] +
[W*.sub.t*x] [W.sub.tt*], is at least as large as -[W*.sub.t*x]
([W.sub.tt]-[W.sub.tt*])> 0 since the term in brackets is negative
from Assumption 1.
Analogous derivations can be used to show d[t*N]/dx* > 0.
Proof of Proposition 6. The threshold [??] is defined by [W.sup.N]
([??]) = [W.sup.C] ([??]). Using expressions (16) and (17), we obtain
the following quadratic function in [??]:
(Al) V[[??].sup.2] +Z[??] + E = 0
with V [equivalent to] -2(1 +[lambda])[(1 -[epsilon])(1 -
[lambda])[S.sup.2] - (2 - [epsilon])S + (1 + [lambda])], Z [equivalent
to] 4[(1 - [epsilon]).sup.2] [S.sup.2] + 4(1 - [epsilon])(1 +
[lambda])[2 - (2 - [epsilon]) S] - [(2 - [epsilon]).sup.2], E
[equivalent to] 2(1-[epsilon])[[epsilon].sup.2], and S [equivalent to] 1
+ 2[epsilon] ([lambda] - [bar.[lambda]]) /(4 - [[epsilon].sup.2]).
Solving expression ((Al)) for r[, selecting the relevant root, yields
[??] = - (Z + [square root of [Z.sup.2] - 4VE]) /2V > 0.
ABBREVIATIONS
FDI: Foreign Direct Investment
LQ: Linear-Quadratic
OECD: Organisation for Economic Co-operation and Development
doi: 10.1111/ecin.12516
Online Early publication November 2, 2017
Dewit: Lecturer, Department of Economics, Finance and Accounting,
National University of Ireland Maynooth, Maynooth, Ireland. Phone
353-1-7083776, Fax 353-17083934, E-mail gerda.dewit@mu.ie
Hynes: Lecturer, School of Economics, University College Dublin,
Dublin 4, Ireland. Phone 353-1-7168386, E-mail kate.hynes@ucd.ie
Leahy: Senior Lecturer, Department of Economics, Finance and
Accounting, National University of Ireland Maynooth, Maynooth, Ireland.
Phone 353-1-7083786, Fax 353-1-7083934, E-mail dermot.leahy@mu.ie
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(1.) The debate on tax competition also often features in the press
(e.g., "Heard that countries should compete on tax? Wrong,"
The Guardian, April 18, 2013).
(2.) Recent empirical work (e.g., Hauptmeier, Mittermaier, and
Rincke 2012; Winner 2012) confirms that governments compete for mobile
capital choosing a multidimensional policy package, consisting not only
of a strategically chosen tax rate, but also of a strategically chosen
level of productive public inputs.
(3.) Recent surveys on tax competition include Zodrow (2010) and
Baskaran and Lopes da Fonseca (2013).
(4.) Examples are Taylor (1992), Bayindir-Upmann (1998), Bucovetsky
(2005), and Egger and Falkinger (2006).
(5.) The setup in these papers is closest to the framework used in
our article. There are, however, important differences between our
article and these studies, which will be discussed when we elaborate on
the specific contributions of our analysis.
(6.) See Chen et al. (2014) for an extension and updated version of
this empirical study.
(7.) More specifically, they found that hub airport expansion has a
significant direct cost savings effect on own-state manufacturing
production, and a roughly equal indirect cost effect on manufacturing
industries in other states.
(8.) In a recent study aimed at determining cross-border spillovers
from European gas infrastructure investment, Bouwmeester and Scholtens
(2017) found that there were significant positive cross-border
spillovers when countries invest in gas transmission infrastructure.
(9.) Consistent with this observation, Alesina and Wacziarg (1998)
show that smaller countries that are more open to trade also have a
larger share of public consumption in gross domestic product.
(10.) This resonates with the findings on the relationship between
corporate tax rates and the provision of public goods in Gorg, Molana,
and Montagna (2009).
(11.) Other theoretical work confirmed this prediction (see Cremer
et al. 1997 for an overview).
(12.) Zissimos and Wooders (2008), Hindriks, Peralta, and Weber
(2008), and Pieretti and Zanaj (2011) examine extremely negative
externalities only, while Dembour and Wauthy (2009) only look at
positive spatial spillovers.
(13.) Previous models of competition for firms typically model that
competition using a Hotelling type setup, implying that the pool of
possible foreign direct investment is fixed and the game prospective
host countries play is a zero-sum game.
(14.) While some papers consider tax harmonization in the sense of
a minimum tax rate or split-the-difference tax rate (Zissimos and
Wooders 2008), others examine fiscal equalization schemes (Hindriks,
Peralta, and Weber 2008) or cooperation in infrastructure (Dembour and
Wauthy 2009).
(15.) Naturally, it is possible that [B.sub.x*] [less than or equal
to] 0 while [B*.sub.x] [greater than or equal to] 0and vice versa.
(16.) The tax revenue from domestic firms comes from domestic
profits and earnings and represents a transfer between agents within the
country. By contrast, tax revenue from multinational firms (captured by
tB) is rent extracted from foreigners and is a net addition to welfare.
Thus, it is important to disentangle the two.
(17.) For instance, the government may be concerned with the
employment they provide or their contribution to export earnings. Thus,
the activity of domestic firms could enter the welfare function
directly. We would expect the direct effect of the tax on domestic firms
to be negative, while the direct effect of local public infrastructure
would be positive for domestic firms.
(18.) On possible crowding out effects of FDI, see, for instance,
Aitkin and Harrison (1999) and Jude (2015).
(19.) A report by the OECD () points to the importance of policies
that maximize the benefits from FDI, especially for newly emerging and
developing economies.
(20.) We have followed the standard practice in assuming that
infrastructure is chosen before the taxes (see among other Zissimos and
Wooders 2008 and Pieretti and Zanaj 2011). The reason for the widespread
preference for this assumption about the move order is that public
infrastructure, which takes time to build, is seen as more difficult to
change than taxes. In another part of the multistage game theory
literature this is the reason why in capacity and price games firms are
modeled as choosing capacity first and then price (e.g., the very
influential paper by Kreps and Scheinkman 1983). In their model, price
is seen as easier to change than capacity. So we assume that governments
set infrastructure first as this variable has more commitment value than
the corporate tax rate because of its innate irreversibility.
(21.) These functional forms allow us to move beyond the Hotelling
case, used in earlier work. The standard Hoteling case implies a fixed
pool of FDI. By contrast, in our setup multinational firms--as indeed
they do in the real world--have an outside option such as producing in
other locations and serving a market from a distance by exporting. What
is more, the Hotelling model restricts [lambda] to -1, which implies a
complete and negative cross-border spillover. By contrast, the
functional forms used here allow us to examine different types and
levels of the externality and assess how beneficial cooperation is in
those different scenarios. This is useful, given that, empirically, the
externality seems to depend on the type of infrastructure and features
of the jurisdictions.
(22.) Brander (1995) was the first to refer to this type of cross
derivative as the "friendliness" term.
(23.) We discuss another form of tax harmonization in Section VI.
(24.) We assume [epsilon] < 1 to ensure an interior cooperative
optimum. This captures the stylized fact that as the cooperative tax
rises it negatively influences the tax base. Note that in the standard
Hotelling case, [epsilon] = 1 and the cooperative (joint optimal) tax
would be confiscatory.
(25.) That is, - [partial derivative]([B.sub.t]t/B)/ [partial
derivative]x = t[B.sub.t][B.sub.x]R/[B.sup.2] <0. This implies R >
0 as [B.sub.t] < 0 and [B.sub.x] > 0.
(26.) Or, r>0 implies the elasticity of H's multinational
tax base does not decrease if F's investment tends to reduce the
gross pretax profits in H.
(27.) There are examples of cross-border cooperation on particular
public infrastructural projects of the type that generate positive
international spillovers. Examples include the United Kingdom, Belgium,
and France cooperating on the Eurostar train link, and Germany and
Denmark cooperating on the Fehmarnbelt tunnel to link the two countries.
Examples of infrastructural cooperation to limit cross border business
stealing are less evident.
(28.) The formal analysis for these extensions is available from
the authors on request.
(29.) The existing literature has identified country asymmetry as a
potential reason why tax harmonization may reduce welfare. Our model
shows that, even when countries are symmetric, tax cooperation may lower
welfare. Here, we show that this result also holds when countries are
asymmetric. This is particularly true for the less attractive country.
Caption: FIGURE 1 First-Order Conditions under Tax Competition and
Tax Cooperation--The Symmetric Linear-Quadratic Case. (A) [lambda] >
[bar.[lambda]], (B) [lambda] < [bar.[lambda]]
Caption: FIGURE 2 Tax Rates and Public Infrastructure Investment
Levels: Tax Competition versus Cooperation--The Symmetric
Linear-Quadratic Case. (A) [lambda] = 0, (B) [lambda]>0, and (C)
[lambda] < [bar.[lambda]]
Caption: FIGURE 3 Welfare under Tax Cooperation and Tax
Competition--The Symmetric Case. (A) Welfare and
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