Exploring Residual Profit Allocation
研究了国际税收改革中剩余利润分配方案的经济影响，发现剩余利润集中在少数跨国公司，对发展中国家税收收入有利，但整体生产效率提升需对常规利润轻征税。
Residual profit allocation (RPA) schemes have come to prominence in discussions of international tax reform but with almost nothing known about their economic impact. These schemes tax multinationals by allocating their “routine” profits to source countries and sharing their remaining “residual” profit across countries on some formulaic basis. This paper explores the implications, conceptual and empirical, of moving to some form of RPA. Residual profits are estimated to be substantial and concentrated in relatively few multinational enterprises. The impact on tax revenue appears beneficial for developing countries. Aggregate production efficiency is unlikely to increase unless routine profits are lightly taxed.