Measuring and Interpreting Countries’ Tax Attractiveness for Investments in Digital Business Models - Intertax View Measuring and Interpreting Countries’ Tax Attractiveness for Investments in Digital Business Models by - Intertax Measuring and Interpreting Countries’ Tax Attractiveness for Investments in Digital Business Models 47 2

This article analyses the tax attractiveness of locations for investments in digital business models. It identifies and assesses relevant tax rules affecting domestic and cross-border digital business models across thirty-three countries. The computation of average effective tax rates is based on the neoclassical investment model of Devereux/Griffith. Our results help to evaluate tax-related location factors in the digital economy by combining the most relevant tax parameters and rules for taxable nexus in an objective measure. We find that investments in digital business models face generally lower average effective tax rates than those in traditional business models since a high share of investment costs is immediately expensed and a higher share of activities falls within the scope of countries’ tax incentives for R&D input and/or output. While more generous depreciation rules for digital investments such as software make countries relatively more attractive, our results are mostly driven by statutory tax rates, special incentive schemes such as Intellectual Property (IP) Boxes, R&D credits, and super-deductions. Overall, we acknowledge an increasing trend in tax competition for digital businesses.

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