Arbeitskreis Quantitative Steuerlehre Quantitative Research in Taxation – Discussion Papers Andreas Dinkel / Deborah Schanz Tax Attractiveness And the Location of Patents arqus Discussion Paper No. 188 April 2015 www.arqus.info ISSN 1861-8944 Tax Attractiveness And the Location of Patents Andreas Dinkel a, Deborah Schanz b 24 April 2015 Abstract: This paper analyzes the impact of taxation on the location of patents within mul- tinational groups. Based on groups with parents from 36 countries globally and their patent holdings in 36 European countries, we provide insight into the determinants of three subse- quent decisions: (1) the decision of whether to locate patents abroad; (2) in which countries to locate patents; and (3) how many patents to locate in each country. Our findings indicate that multinationals take the tax attractiveness of countries into account when making these decisions. Specifically, we show that the statutory tax rate, the taxation of royalties, R&D incentives, and transfer pricing rules help to explain the patent-location choices of multina- tionals. Keywords: International taxation; Tax attractiveness; Intellectual property; Location deci- sion; Multinational enterprise. JEL classification: H25, H73, F23. a Munich Business School, Ludwig-Maximilians-University Munich, Ludwigstraße 28/RG IV, D-80539 Munich, Germany, E-Mail:
[email protected], Phone: +49 89 2180 6084. b Prof. Dr., Munich Business School, Ludwig-Maximilians-University Munich, Ludwigstraße 28/RG IV, D-80539 Munich, Germany, E-Mail:
[email protected], Phone: +49 89 2180 3681. 1 1 Introduction With the transition from agricultural economies to knowledge-based service and man- ufacturing economies, the importance of patents has increased considerably.