Large multinational companies are regularly suspected of using transfer pricing of intangibles to shift profits from high- to low-tax jurisdictions. We study the optimal transfer prices while endogenizing the location choice of intangibles and considering spillovers. In line with the initial intuition, we find that multinationals locate their intangibles in low-tax jurisdictions and deploy royalty flows to minimize tax payments. However, if multinationals face a trade-off between tax minimization and efficient spillover internalization, the so-called "home bias" might occur. Then, for a large spillover, the intangible is optimally located in the high-tax domestic country. This leads to less severe investment distortions because the spillover is internalized. In addition, the model predicts that curtailing profit shifting possibilities can either harm or facilitate multinationals' overall investments. This depends heavily on unobservable factors such as the underlying accounting system. Therefore, our analysis highlights challenges for the anti-avoidance legislation of governments. / Series: WU International Taxation Research Paper Series

Submitted by Fabio Sobreira Campos da Costa (fabio.sobreira@ufpe.br) on 2016-09-05T15:32:56Z No. of bitstreams: 2 license_rdf: 1232 bytes, checksum: 66e71c371cc565284e70f40736c94386 (MD5) Dissertação_Bruno Andrade.pdf: 1074192 bytes, checksum: 8d81eef1869977ddc28d7fa412aa1089 (MD5) / Made available in DSpace on 2016-09-05T15:32:57Z (GMT). No. of bitstreams: 2 license_rdf: 1232 bytes, checksum: 66e71c371cc565284e70f40736c94386 (MD5) Dissertação_Bruno Andrade.pdf: 1074192 bytes, checksum: 8d81eef1869977ddc28d7fa412aa1089 (MD5) Previous issue date: 2016-02-29 / FACEPE / Esse trabalho tem como objetivo investigar a influência de fatores locais, tais como, potencial de mercado, custo da produção e, principalmente, de economias de aglomeração (externalidades marshallianas), nas decisões de localização das firmas formais da indústria têxtil e de confecção do estado de Pernambuco. Num primeiro momento, são obtidas informações sobre a gênese e crescimento recente dos segmentos em estudo, além da identificação da aglomeração espacial e especialização produtiva desses segmentos no âmbito das microrregiões do estado. Posteriormente, a partir dos microdados ao nível da firma da Relação Anual de Informações Sociais (RAIS), para o período de 2006 a 2010, é efetuada a estimação do modelo de escolha discreta logit condicional. Os principais resultados sugerem que as firmas do setor têxtil-confecção do estado desfrutam das vantagens associadas à aglomeração, principalmente daquelas provenientes da especialização setorial. / This study aims to investigate the influence of local factors, such as market potential, cost of production and, especially, of agglomeration economies (marshallians externalities), in the location decisions of formal firms in the textile and apparel industry of Pernambuco state. At first, information are obtained about the genesis and the recent growth of the segments under study, as well as identifying spatial agglomeration and productive specialization of these segments within the micro-regions of the state. Later, from the micro level dates of the firm provided by RAIS, for the period 2006 to 2010, it is made the estimation of discrete choice model conditional logit. The main results suggest that firms in the textile-apparel sector of the state enjoy the advantages associated with agglomeration, especially those from the sectoral specialization.

Background: Inequity in general practice workforce distribution remains a significant issue despite the increasing numbers of general practitioners (GPs) in the UK. Problems with recruitment and retention in England are particularly evident in urban deprived areas. The aim of the current study was to explore affinity for working in urban deprived areas, focusing on practitioners’ background, values and care orientation. Methods: There were two stages to the research: 1) semi-structured qualitative interviews with 25 GPs and practice nurses to explore their background, values and care orientation in relation to location; 2) questionnaire survey with approximately 1200 GPs and practice nurses to determine the association between affinity factors and current location. The sample of practitioners was drawn from general practices located in the most and least deprived areas in the northwest region of England. Results: 25 qualitative interviews were conducted and the data analysed using a framework analysis approach. The analysis indicated that location preferences were formed early in practitioners’ careers. While an overt affinity for deprived areas was more likely among GPs, pragmatism could dominate location decisions for all. The narrative of practitioners in deprived areas suggested benevolent, universalistic and stimulation personal values, and a patient-centred care orientation. Satisfaction derived from making a difference, having a challenge, addressing social injustice, and having a sense of belonging. Coping strategies included: structure and organisation, support from colleagues, emotional detachment, reassessment of expectations, and distraction. The response rate to the postal questionnaire survey was 30.9% for GPs and 41.2% (practice level) for nurses. Although there were few differences in the personal values of practitioners working in deprived and affluent areas, there were more differences in specific work values. Stepwise logistic regression showed that for GPs, determinants of working in a deprived area included: having trained in a deprived area; not being influenced by the convenience of the location in choosing their current practice; and valuing control in decision-making. For nurses, determinants included: having worked in a deprived area before; not being influenced by quality of care in the practice when choosing their current practice; and not valuing being respected by practice colleagues. Subgroup analyses suggested different predictors for practitioners with different role status: GP principals were more likely to work in a deprived area if they valued providing care to those in greatest need of help, in addition to having trained in a deprived area. Discussion: The training location of GPs was a consistent factor in determining current location. This differs from the literature on location choice in rural and remote areas, for which childhood exposure is considered to be the dominant factor. Differences in personal values were reflected more clearly in specific work values. Future research should look at how GPs choose their training practice and how such experiences could be exploited to enhance recruitment to underserved urban areas. Strategies to aid retention could look to the coping strategies employed by practitioners to deal with the demands of working in a deprived area.

The extant literature had studied the determinants of the firms’ location decisions with help of host country characteristics and distances between home and host countries. Firm resources and its internationalization strategies had found limited attention in this literature. To address this gap, the research question in this dissertation was whether and how firms’ resources and internationalization strategies impacted the international location decisions of emerging market firms. To explore the research question, data were hand-collected from Indian software firms on their location decisions taken between April 2000 and March 2009. To analyze the multi-level longitudinal dataset, hierarchical linear modeling was used. The results showed that the internationalization strategies, namely market-seeking or labor-seeking had direct impact on firms’ location decision. This direct relationship was moderated by firm resource which, in case of Indian software firms, was the appraisal at CMMI level-5. Indian software firms located in developed countries with a market-seeking strategy and in emerging markets with a labor-seeking strategy. However, software firms with resource such as CMMI level-5 appraisal, when in a labor-seeking mode, were more likely to locate in a developed country over emerging market than firms without the appraisal. Software firms with CMMI level-5 appraisal, when in market-seeking mode, were more likely to locate in a developed country over an emerging market than firms without the appraisal. It was concluded that the internationalization strategies and resources of companies predicted their location choices, over and above the variables studied in the theoretical field of location determinants.

In this article, we propose an innovative way of delineating local markets based on easily accessible data. We apply this concept to the day care industry and investigate providers' location choices relative to local market characteristics to evaluate the widespread presumption that local markets for child care services are geographically very small. Using a panel of all day care centers for the metropolitan region of Vienna, Austria, for nearly a decade, as well as geographically extremely disaggregated data on the spatial distribution of children under the age of six at the 250m×250m grid cell level, we find that the location of children and day care centers are strongly related, but this relationship diminishes as soon as the distance between a child's place of residence and the day care center's location increases. We conclude that local markets for day care services in metropolitan regions are indeed very small (about 500m or 550 yards).

This thesis contains explanations about the reasons why residents prefer apartment housing to low rise housing far away from the central business district. And it also investigates the facts that affect residents&rsquo / and producers&rsquo / apartment housing choice. As a dominant housing provision type, apartment housing is produced every location in urban space in Ankara. Therefore the study begins with investigating the formation and growth of apartment housing in Ankara by introducing spatial variation of apartment housing. With the help of building and population censuses, distribution of 400 quarters in the Greater Ankara Municipality borders with respect to building and population density, building features, share of apartment housing and average number of storeys are analyzed. FAR values are calculated and analyzed from the CBD to western direction to introduce the change in building densities. Lastly a questionnaire survey is done to find out whether differentiation of building and environment attributes of apartment housing that are produced in different location of urban area are well-matched with their residents&rsquo / preferences. At the end of the analysis differentiation of housing structure of the city clearly comes out. While it is expected that the height of housing structure is decreasing by going far away from the CBD, it is found increasing along certain directions such as western and south-western. However by moving at western direction FAR decreases from 2 to 0,75 which states different characteristics of housing structure even if high average number of storey. As a result apartment housing provisions at different locations offer different lifestyles with their building and environmental characteristics.

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為研究地主國租稅環境對台灣跨國企業海外子公司區位選擇的影響，本文以巢式羅吉特模型研究 2001 年至 2013 年間台灣上市櫃公司海外關係企業（排除金融保險業和 F 股）的資料。相對於過去探討海外子公司區位選擇的文獻僅著重於地主國稅率和地主國是否有反避稅制度（移轉訂價制度和資本弱化條款），本文首度加入租稅協定相關的變數：「地主國是否與台灣簽訂租稅協定」和「地主國租稅協定網絡」，探討兩者與海外子公司區位選擇的關係。 本研究實證結果發現地主國與台灣簽訂租稅協定並不能增加海外子公司在該地設立的機率，反而可能因租稅協定中的資訊交換條款而降低在該地設立子公司的機率；地主國租稅協定網絡愈豐富則是會增加跨國企業在該地設立海外子公司的機率，表示跨國企業可能藉由設立在租稅協定網絡豐富國家的海外子公司，適用該國的租稅協定利益。其他與地主國租稅環境相關變數的實證結果為潛在地主國稅率愈低及無反避稅制度的國家會較吸引海外子公司的設立。 / Using nested logit model, the thesis examined the impact of international taxation on location choice of Taiwanese multinational firms from 2001 to 2013. Compared to previous studies that only focused on the impact of tax rate and anti-avoidance legislations (transfer pricing rule and thin capitalization prvision), the thesis focused on the impact of tax treaty, examining the relationship between location choice and bilateral or multilateral tax treaties. The results showed that countries which had tax treaty with Taiwan did not attract Taiwanese multinational firms, and the possible reason was the exchange of information article in tax treaties. The study also found that the more tax treaties one potential host country had, the higher probability of Taiwanese multinational enterprises setting up subsidiaries in that host country, which suggested that Taiwanese multinational enterprises may have the behavior of treaty shopping. Other results related to tax variables showed that potential host countries with lower tax rate or with no anti-avoidance legislations would attract Taiwanese multinational firms.

Cette thèse, portant sur le choix de localisation résidentielle des ménages, s’inscrit dans le cadre théorique de la microéconomie urbaine et de l’utilité aléatoire. Si l’approche des choix discrets reste la plus appropriée dans ce domaine, la difficulté réside dans l’adaptation de ce type de modèles au contexte spatial (autocorrélation spatiale, grand nombre d’alternatives de choix) d’une part, et dans la manière de définir l’échelle de désagrégation d’autre part. Pour ce faire, nous avons procédé en deux temps. Nous avons estimé un logit multinomial avec un échantillon aléatoire d’alternatives pour comprendre le processus de choix de localisation résidentielle, avant de tester l’apport d’une structure hiérarchique pour traiter les problèmes d’autocorrélation spatiale. Cela a aussi permis l’investigation d’une nouvelle méthode de correction des biais liés à l’échantillonnage d’alternatives dans le cas du modèle logit emboîté. En termes de résultats, nous avons montré que la qualité de l’environnement social est le facteur le plus déterminant, sans remettre en cause le poids toujours important de l’accessibilité à l’emploi. Au plan méthodologique, nous avons été en mesure de tester l’apport de l’utilisation d’un modèle logit emboîté pour analyser les choix de localisation de l’aire urbaine de Lyon. Cependant, nous n’avons pas pu dépasser la difficulté de séparer l’autocorrélation spatiale et entre les nids. Le calage du modèle de choix de localisation en 1999 et en 2007 a aussi permis de donner des éléments de réponse sur la transférabilité temporelle des modèles de choix de localisation et de questionner, dans les travaux futurs, le pouvoir prédictif d’un modèle de choix de localisation. / This thesis, focusing on the choice of residential location, is based on the theoretical framework of urban micro-economy and random utility. Though discrete choice modelling is the most appropriate in this field, the difficulty lies in choosing the appropriate model to the spatial context of residential location choice (spatial autocorrelation, large number of alternatives), on the one hand, and in the way of defining the spatial scale, on the other hand. For this purpose, we proceeded in two stages. We estimated a multinomial logit with random sampling of alternatives to understand the process of residential location choice before taking into account the spatial autocorrelation, and estimating a nested logit model. It also allowed to investigate the feasibility of applying a new method to correct biases of sampling alternatives in the case of nested logit model. In terms of results, we have shown that social environment are the most important determinants of residential location choice. Though job accessibility still weigh on household choice decision. In terms of methodology, we were able to test the feasibility of estimating a nested logit model with sampling of alternatives to analyze the choice of location of Lyon urban area. However, we could not overcome the difficulty of distinguishing spatial autocorrelation from nesting. The use of 1999 and 2007 databases to model residential location choice also helped to provide answers on the temporal transferability of location choice models and discuss in future work the predictive power of a location choice model.

This thesis consists of an introductory part and four papers. Paper [I] estimates jointly the choice of whether to enroll in education and the choice of location among young people. Being a particularly mobile group, the location choices of young individuals shape much of the regional distribution of human capital, growth, and local public sector budgets. Applying Swedish register data on nest leavers, we seek to determine factors deciding the education and location choice of young people. The results indicate a systematic selection higher education based on school grades and preferences for locations with higher per capita tax bases and with lower shares of elderly people. The importance of family networks for the choice of location is confirmed.              Paper [II] examines how individual ability, reflected by the grade point average (GPA) from comprehensive school affects the probability of migration among university graduates. The econometric analysis applies detailed micro-data of two entire cohorts of young individuals retrieved from the Swedish population registers. The results indicate that individual abilities are strongly influential both concerning completion of a university degree and for the migration decision. In addition, we find a positive relationship between the GPA and migrating from regions with lower per capita tax bases and/or a relatively small share of highly educated individuals. Analogously, individuals with a high GPA tend to stay in more densely populated regions, suggesting a clustering of human capital vis-à-vis school grades.  Paper [III] estimates the relationship between migration across labour market regions and the subsequent changes in earnings by using the GPA from the final year of comprehensive school as a proxy for ability. This measure aims to capture heterogeneity in the returns to migration for individuals conditional on education attainment. Using Swedish register data on young adults, a difference-in-difference propensity score matching estimator is applied to estimate income differences measured up to seven years after migration. The results show variation between different ability groups regarding the returns to regional migration. There are indications of larger gains for individuals holding top grades, while the bottom half seems to benefit less, or face slightly negative effects. Paper [IV] examines whether power couple formation and the location choice of such couples are driven by factors already inherent in young people during their formative school years. The paper also extends the analysis by modeling location choice among different sizes of labor market areas, given different power statuses of the couples. Based on analysis of Swedish register data, we produce evidence that power spouses evolve from the population of high achieving school age individuals; the latter is identified by high academic performance during their years of compulsory school. Regarding location choice, the results indicate that power couples display a relatively high tendency to migrate from their regions of origin to large cities.