Michael Keen
Fiscal Affairs Department
International Monetary Fund
Washington, DC
USA
and
David E. Wildasin
Martin School of Public Policy
and
Department of Economics
University of Kentucky
Lexington, KY 40506-0027
USA
Abstract
This paper addresses a key but neglected task in the theory of
international taxation, lent increased urgency by growing awareness of the
potential gains from tax coordination: the characterization of
Pareto-efficient international tax regimes. It shows that the
Diamond-Mirrlees theorem on the desirability of production efficiency,
which underlies the key tenets of policy advice in international
taxation---the desirability of destination basis for commodity taxation, of
the residence principle for capital income taxation, and of free trade---is
rendered inherently inapplicable to problems of international tax design by
the distinctness of national budget constraints that is of the essence in
thinking about international taxation. Conditions are
established---relating to the availability of explicit or implicit devices
for reallocating tax revenues across countries---under which production
efficiency is nevertheless desirable, and a general characterization
developed of the precise ways in which Pareto efficient international
taxation may require violation of established tenets.