Abstract
In many industries like consulting or construction, highly qualified employees, i.e., experts or executive managers, have to be assigned to temporary projects. Obviously, the employees’ productivities in the respective projects are crucial for the employer’s optimal assignment decision, but assignment can also be affected by risk-incentive trade-offs. Moreover, taxation can alter the assignment decision, especially if employees are sent abroad as expatriates so that international tax law has to be taken into account. To address these issues simultaneously, we combine a human resource assignment problem with a principal–agent problem of the LEN type. Both wage taxation at the agents’ level and corporate taxation at the principal’s level are integrated. We show that national tax rules, the methods for avoiding double taxation, and the agents’ tax characteristics are important determinants of international assignment decisions. The effects of tax rate variations can be ambiguous and depend on whether the exemption method or the credit method are applied, in particular if agents make differing choices of residence. From a tax policy perspective, the exemption method should be preferred as the tax effects are more transparent and intuitive than under the credit method.
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Notes
This research gap is rather surprising given current levels of individual and corporate income taxes in OECD countries and the resulting potential tax rate differentials. In the OECD countries, top statutory personal income tax rates were between 15.0 and 60.2 % with an average of 42.5 % in 2012 and corporate tax rates between 12.5 and 39.1 % with an average of 25.5 % in 2013; see OECD (2013a, b).
See, e.g., Voßmerbäumer (2013) and the references cited therein.
To see this denote actual effort costs \(\tilde{e}_{ij}/\alpha _{ij}\) and the actual productivity parameter \(\tilde{\pi }_{ij}\). Rescale the unit in which effort is measured according to \(e_{ij} = \sqrt{2/\alpha _{ij}} \tilde{e}_{ij}\), and hence effort costs amount to \(\tilde{e}_{ij}^2/\alpha _i = e_{ij}^2/2\). The job’s return, \(\tilde{\pi }_{ij} \tilde{e}_{ij}\), then amounts to \(\tilde{\pi }_{ij} \sqrt{\alpha _{ij}/2} e_{ij}\). The required rescaling of the productivity parameter is therefore \(\pi _{ij} = \sqrt{\alpha _{ij}/2} \tilde{\pi }_{ij}\).
But, to simplify the analysis and the exposition, the model does not include tax-deductible effort costs nor fixed profits or fixed agent costs.
See Article 15 No. 2 of the OECD model tax convention. The assumption of a long-term assignment is typically met for expatriates. Moreover, in the construction industry long-term building sites are regularly considered as permanent establishments; cf. Article 5 No. 3 of the OECD model tax convention.
We assume that a double taxation convention between the home country and the host country exists. Therefore, we neglect the case of unrelieved double taxation.
In principle, the agent’s decision to move his center of vital interests could be modeled endogenously by productivity coefficients \(\pi _{ij}\) depending on this decision. However, to keep the model simple, we assume an exogenously given center of vital interests.
See Article 15 of the OECD model tax convention. Throughout the paper we do not take the nationality principle into account. This principle means that taxpayers are taxed according to their citizenship. Except for the U.S., the nationality principle is rarely applied.
See, e.g., Articles 23A, 23B of the OECD model tax convention. Jacobs et al. (2005) give an international overview of the taxation of expatriates.
We neglect carrybacks or carryforwards of foreign tax credits and do not distinguish between a worldwide or a per-country limitation. See, e.g., Blouin (2012, pp. 10) for the US case.
See Articles 15, 24 (2) of the double taxation convention between Austria and the UK and Articles 15, 23 (2) of the double taxation convention between Austria and Germany.
See Articles 15, 23 (2) of the double taxation convention between Croatia and Austria and Articles 15, 23 (2) of the double taxation convention between Croatia and Germany.
See Burkhard et al. (2012, §§1.2, 4). In particular, the costs in the canonical LSAP formulation associated with the assignment of agent i to job j can be defined as \(-(1-\tau _j) P_{ij} + \max _{i,j} (1-\tau _j) P_{ij}\).
Income from the home country as well as the exemption-with-progression method are neglected here.
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Appendix
Appendix
Proof of Proposition 6 (1) “If” part: Evaluating (9) for \(\tau _1=\tau _2\) and \(t_{11}=t_{12}=t_{21}=t_{22}=0\) yields (22).
(2) “Only if” part: By definition, tax neutrality implies the equivalence of optimality conditions (9) and (22) for all \(\pi _{ij}\) and \(\underline{u}_{i1}=\underline{u}_{i2}\). With \(\underline{u}_{i} \equiv \underline{u}_{i1}=\underline{u}_{i2}\), the optimality conditions (9) and (22) are equivalent only if
Rearranging and simplifying this condition yields
which holds for arbitrary reservation remunerations \(\underline{u}_i\) if and only if the terms in parentheses vanish. Thus, the conditions
and
hold.
Exploiting these conditions to simplify (9) results in
This optimality condition, in turn, is equivalent to (22) for arbitrary productivity parameters \(\pi _{ij}\) if and only if
and
Conditions (37) and (41), in turn, imply \(\tau _1=\tau _2\) and \(t_{11}=t_{12}\), and hence we have shown that tax neutrality holds only if \(\tau _1=\tau _2\) and \(t_{11}=t_{12}=t_{21}=t_{22}\). As tax neutrality does not hold for \(\tau _1=\tau _2\) and \(t_{11}=t_{12}=t_{21}=t_{22}>0\), tax neutrality implies \(\tau _1=\tau _2\) and \(t_{11}=t_{12}=t_{21}=t_{22}=0\).\(\square \)
Proof of Corollary 1 After exploiting Assumption 2 to simplify condition (9), the proof follows the same lines as that of Proposition 6 and is therefore omitted. The crucial difference is that the equivalence of the simplified condition (9) and condition (22) also holds for \(\tau _1=\tau _2\) and \(t_{11}=t_{12}=t_{21}=t_{22}>0\). \(\square \)
Proof of Corollary 2 After exploiting Assumption 3 to simplify condition (9), the proof follows the same lines as that of Proposition 6 and is therefore omitted. The crucial difference is that only conditions (40) and (41) remain. \(\square \)
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Martini, J.T., Niemann, R. The impact of taxation on international assignment decisions: a principal–agent approach. Rev Manag Sci 9, 703–729 (2015). https://doi.org/10.1007/s11846-014-0134-8
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DOI: https://doi.org/10.1007/s11846-014-0134-8