THE TAX TREATMENT OF RESEARCH-AND-DEVELOPMENT EXPENDITURES OF MULTINATIONAL-ENTERPRISES

This paper investigates the tax treatment by national governments of R&D expenditures of multinational enterprises. In a noncooperative world, the international tax system is generally shown to discourage R&D investments by multinational firms. For the special case of symmetric corporate tax rates, the multinational is allowed to expense less than the total of its R&D expenses worldwide. Internationalization of the firm's operations and ownership is demonstrated to lead to less generous expensing rules within individual countries, and may even eliminate R&D tax deductions altogether.