Reassessing the Economic Allegiance Theory from a Transaction Cost Perspective: What’s the Benefit Principle Got to Do with It?

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This article challenges the orthodox view that the benefit (or exchange) theory provides the intellectual foundation of international taxation and that the economic allegiance theory represents a special version of the benefit principle. Rather, according to transaction cost economics (TCE), international taxation reflects the highly relational nature of international investments, as measured by (i) the duration of the taxpayer’s engagement with the relevant states; (ii) the uncertainty of benefits; and (iii) the asset specificity of the engagement. This relational perspective is reflected in the concept of economic allegiance, which depicts the taxpayer’s relational engagement with relevant states, either through wealth production (source jurisdiction) or wealth consumption (residence jurisdiction). This new construction of the economic allegiance theory may provide a holist analytical framework for international taxation and inform the debates of various treaty issues in a consistent way.

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Academy of Management JournalVol. 56, No. 4 From the EditorsIntegrating Theories in AMJ ArticlesKyle J. Mayer and Raymond T. SparroweKyle J. MayerUniversity of Southern CaliforniaWashington University and Raymond T. SparroweUniversity of Southern CaliforniaWashington UniversityPublished Online:26 Jul 2013https://doi.org/10.5465/amj.2013.4004AboutSectionsView articleView Full TextPDF/EPUB ToolsDownload CitationsAdd to favoritesTrack Citations ShareShare onFacebookTwitterLinkedInRedditEmail View articleREFERENCES Argyres N. S. , Zenger T. R. 2012. Capabilities, transaction costs, and firm boundaries. Organization Science, 23: 1643–1657. Google Scholar Blau P. 1964. Exchange and power in social life. New York: Wiley. Google Scholar Brass D. J. 1984. Being in the right place: A structural analysis of individual influence in an organization. Administrative Science Quarterly, 29: 518–539. Google Scholar Bunderson J. S. 2003. 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J. , Salomon R. M. 2006. Capabilities, contractual hazards, and governance: Integrating resource-based and transaction cost perspectives. Academy of Management Journal, 49: 942–959.Link , Google Scholar Organ D. W. 1990. The motivational basis of organizational citizenship behavior. In Staw B. M.Cummings L. L. (Eds.), Research in organizational behavior, vol. 13: 43–72. Greenwich, CT: JAI. Google Scholar Robinson S. L. , Morrison E. W. 1995. Psychological contracts and OCB: The effect of unfulfilled obligations on civic virtue behavior. Journal of Organizational Behavior, 16: 289–298. Google Scholar Rousseau D. M. , McLean Parks J. 1992. The contracts of individuals and organizations. In Staw B. M.Cummings L. L. (Eds.), Research in organizational behavior, vol. 15: 1–43. Greenwich, CT: JAI. Google Scholar Sparrowe R. T. , Liden R. C. 2005. Two routes to influence: Integrating leader-member exchange and social network perspectives. Administrative Science Quarterly, 50: 505–535. Google Scholar Weber L. , Mayer K. J. 2011. Designing effective contracts: Exploring the influence of framing and expectations. Academy of Management Review, 36: 53–75.Link , Google ScholarFiguresReferencesRelatedDetailsCited byNew Ways of Seeing: Radical TheorizingSucheta Nadkarni, Marc Gruber, Katy DeCelles, Brian Connelly and Markus Baer5 March 2018 | Academy of Management Journal, Vol. 61, No. 2 Vol. 56, No. 4 Permissions Metrics in the past 12 months History Published online 26 July 2013 Published in print 1 August 2013 Information© Academy of Management JournalDownload PDF

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PurposeThis study aims to explore the reasons behind the lengthy delays in completing a single public-private partnership (PPP) project in Indonesia and investigates how the transaction costs play a significant role in hindering the project’s success.Design/methodology/approachTo broaden insight into the transaction cost theory, the authors used a single case study approach to provide a more in-depth analysis of a context whose complexity can be fully explored. As the primary data sources, 16 face-to-face semi-structured interviews were conducted with the stakeholders directly involved in the project’s initiation, design and execution.FindingsThis case study demonstrates that transaction cost issues, both political and economic, play a significant role. This study has identified four main problems associated with transaction costs hindering project success, namely, executing agencies’ lack of knowledge and experience, lack of coordination for such a complex governance structure that links too many stakeholders and the financial and political risk that increase the uncertainty and public distrust.Research limitations/implicationsThis study contributes mainly to the PPP and transaction costs economics literature, providing empirical evidence on why major PPP projects may fail to be procured. The Greater Bandung waste to energy (WTE) Project case demonstrates that transaction costs, both political and economic, have played a significant role in the lengthy delay of the PPP project.Practical implicationsAs the project involves many transaction cost issues, mapping the failure factors at the project sites can significantly contribute to the practitioners/stakeholders involved in the PPP WTE projects. Therefore, this study provides a lesson to the policymakers at all levels interested in PPPs to consider the issues of transaction costs related to the PPP projects. It can be used as guidance as well as a reference for future PPP WTE projects in Indonesia.Social implicationsMapping the failure factors also signifying the response of the public in the PPP WTE projects undertaken. As the citizens become more rule-conscious and rights-conscious, they demand the opportunity to participate in creating rules and project plans. If the project failed to consult with affected communities and undermined democratic accountability, the angry citizens will confront the government to cancel the project. Therefore, political and economic influences for public attitude play significant roles in making the PPP WTE projects successful.Originality/valueThis study provides insight into the transaction cost issues that have hindered the completion of Indonesia’s PPP WTE project over the past 15 years. Additionally, the project feasibility analysis should include an understanding of transaction costs for partnering in PPP.

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