ETPF Public Conference 2016, in partnership with the Institute for Fiscal Studies

BEPS and Beyond
18 April 1016
RICS, 12 Great George Street, London, SW1P 3AD

Mike Devereux presented the initial findings from the ETPF’s Uncertainty Survey, which ran from January to March 2016. Fergus
Harradence (UK Treasury) responded to the findings. The results of the survey were well received, as empirical data to support claims
on uncertainty being harmful are hard to come by. Among other things, the results showed that BRIC countries take up 4 of the top 5
places in corporation tax uncertainty, and the top 4 places in effects of CT uncertainty on business decisions. Additionally, the survey
showed that CT uncertainty has increased in 20 out of 21 countries in the last 5 years.

We then had presentations from two academics, Catie Magelsson and Simon Loretz about their papers on Where do Multinationals
hold intangible assets, and why? and Co-location of tangible and intangible assets, respectively, with a response from Helen Miller of
IFS. Catie’s database of 40,001 data points from transfer pricing reports of over 100 companies allows interesting comparison of
different types of intangibles (tacit/codifiable and independent/complementary) and demonstrates that the vast majority of companies
holding IP perform value creating activities. Simon’s publicly available data set is much larger and he has undertaken further work to
seek to match this to patent registrations to determine which intangibles may actually be involved in receiving taxable royalty returns,
and where they are located. Simon’s initial conclusion is that there are more instances of locating intangibles alongside tangible
assets than the other way around.

Mike Devereux presented the first of our 2016 Policy Papers, Economic Theory of the Optimal Taxation of Multinational Profit. The paper
discusses the traditional approaches of the optimal tax treatment of international investment and concludes that in the modern world it
could be more economically efficient to levy tax in the country where goods and services are ultimately sold.

Irem Guceri presented the second of our 2016 Policy Papers, How effective are tax incentives for Research & Development? The paper
discusses the existing literature that identify the benefits and costs of different types of R&D incentives, and the broader benefits that
spill over into society from R&D. The findings to date suggest there is a positive reaction to R&D incentives of between 4% and 23% of
the cost, but that more research is needed to identify more nuanced considerations such as effects of productivity, cross country
differences, composition, and whether in an international context the incentives form part of a zero sum game.

Policy Papers
5  Tax Incentives for R&D
6  Economic theory of the optimal taxation of multinational profit

Previous Events
ETPF Public Conference 2012
ETPF Public Conference 2013
ETPF Public Conference 2014
ETPF Public Conference 2015

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