Why do countries change the taxation of foreign-source income of multinational firms?

Abstract

Why do some countries continue to tax income that multinational firms create overseas, even as other countries increasingly adopt a system that only taxes income generated within the country? I argue that this phenomenon reflects an interaction between trade openness and the number of veto players. Increasing trade openness incentivizes governments to move to a territorial tax system, because firms that operate across borders want to avoid various tax liabilities in multiple countries. Yet countries with fewer veto players are more likely to move to a territorial tax system than those with many veto players. To test my hypothesis, I employ survival and logistic regression analyses of 15 advanced industrialized countries between 1981 and 2013. Overall the findings conform to the expectation: Economically open countries with fewer veto players are more likely to shift to a territorial tax system than those with many veto players.