Rozwój Regionalny i Polityka Regionalna 62: 303–323
https://doi.org/10.14746/rrpr.2022.62.17
2022
Agnieszka Teterycz1, Anna Białek-Jaworska1*, Michał Woźniak1,
Monika Piosik2
1
Uniwersytet Warszawski, Wydział Nauk Ekonomicznych
AT: agnieszka.teterycz1@gmail.com,
https://orcid.org/0000-0002-4346-6746
ABJ: abialek@wne.uw.edu.pl,
https://orcid.org/0000-0003-4520-8916
MW: mj.wozniak9@uw.edu.pl,
https://orcid.org/0000-0001-7313-864X
2
Szkoła Główna Handlowa, Warszawa
MP: mp64054@doktorant.sgh.waw.pl,
https://orcid.org/0000-0003-2885-5927
* corresponding author
Do gaming companies benefit from
the IP Box tax rate? Multinational, Polish
and Wielkopolskie voivodeship perspective
Abstract: This article aims to verify the impact of the reduced IP Box tax rate on the
revenues of gaming companies and Gibrat’s Law stating that firm growth is independent
of a company’s size. The dynamic panel-data models estimated in this article using GMM,
FE panel data and OLS methods were created based on data of 673 companies from 11
countries. We show that small gaming firms are growing faster than their larger rivals.
Thus, we reject Gibrat’s Law. We did not find evidence that IP Box supports the firm’s
growth except for the Wielkopolskie Voivodeship. More chances for IP Box’s (reduced to
5% income tax rate being in force in Poland since 2019) effects are given to firms with
more remarkable and dynamic changes in capital intensity, intangibility and inventory.
The gaming industry in Wielkopolska benefits more from IP Box than the rest of Poland.
Key words: IP Box, gaming sector, companies growth
Introduction
The global gaming industry has grown rapidly in recent years. However, it is
characterised by a remarkably short lifetime, and most mobile games’ downloads
peak during the service’s early period. Acquiring as many users as possible immediately after the launch and retaining these users, therefore, becomes very important for mobile game sales (Nam, Kim 2020). The structure of classic games
comprises four stages: development or production, commercialisation or pub-
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Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
lishing, distribution, and customer engagement (Aleem et al. 2016), while the
mobile game ecosystem consists of three stages – creation, delivery and use. Developers produce a game, game publishers distribute it on mobile app platforms,
i.e., Google Play and Apple’s App Store, and finally, users download and enjoy
the game (Feijoo et al. 2012). Nowadays, the most popular mobile games are
experience goods. This is because although users expect to experience fantasies,
feelings, and fun by playing them (Holbrook, Hirschman 1982, Schmitt 1999),
they do not recognise their real value until they experience it (Shapiro et al.
1998). Thus, one of the critical properties of mobile games as an experience good
is that the information a user can obtain is very limited until the game is released
and downloaded. Their choice to download depends on their expectations. This
implies that the users’ information-seeking behaviour before experiencing the
mobile game and the game publishers’ market strategy should significantly influence the mobile game’s sales (Nam, Kim 2020). The gaming sector solely in Poland is also constantly growing by 30% year-on-year (YoY) growth in 2016–2019
(PARP 2021).
Over the last 20 years, 14 out of 27 European countries have applied IP Box
regimes to enable firms to cut the tax rate on income earned from successful
innovation (Lester 2021) emerging from various forms of intellectual property
(Evers et al. 2015, Merrill 2016). Because multinational enterprises have more
opportunities to reap tax benefits than domestic firms (Karkinsky, Riedel 2012).
Koethenbuerger et al. (2018), Bornemann et al. (2020), Karkinsky and Riedel
(2012), and Chen et al. (2019) examine how the IP Box affects locations of intangible assets or R&D, cross-border payments and reported income. Bradley
et al. (2015), Evers et al. (2015), Mohnen et al. (2017), Chen et al. (2019), and
Haufler and Schindler (2020) find that IP Box boosts firms’ innovative activities
and investments in R&D. But Gaessler et al. (2021) provided evidence that IP
Box negatively impacts local invention and R&D when there is no requirement
for further development but insignificant otherwise. Therefore, learnt by experience, OECD introduced the Base Erosion and Profit Shifting (BEPS) restrictions.
Results obtained by Gaessler et al. (2021) call into question whether the IP box
is an effective instrument for encouraging innovation in a country rather than
simply preventing or facilitating the shifting of corporate income to low-tax jurisdictions. However, nexus rules reduce firms’ incentives for acquiring developed
intangibles and, by extension, reduce the number of Mergers and Acquisition
activity as it requires actual action in exchange for tax benefits (Lester 2021),
among others, in Poland.
In Poland, IP Box (lower – amounting to a 5% tax rate for income obtained
from qualified intellectual property rights) has been available since the beginning
of 2019. Under certain conditions (mainly through developing copyrighted software – one of the qualified IP rights), IP Box can be applied by companies producing and developing software in the gaming sector (Prokurat 2020). The number of IP Box taxpayers since 2019 in Wielkopolskie Voivodeship is significantly
growing, much more among Personal Income Tax (PIT) taxpayers than Corporate
Income Tax (CIT) taxpayers. Due to the construction of the Nexus ratio, the
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
305
Polish IP Box regime supports taxpayers who conduct the R&D works leading to
developing the qualified IP by themselves. It can be stated that this tax preference
helps to develop the internal companies’ creativity, operations and products. The
gaming sector links ICT with the art and creative industry. Therefore it is vital
to notice the relationship between creativity and the possibility of (innovative)
idea implementation. Firstly the ability to produce creative ideas is more common than the actual implementation of innovations (West 2002). Dissanayake
et al. (2018) suggest that creativity and innovations are firmly integrated, but
creativity does not guarantee (the victorious) implementation of the idea. Synergies between creative and technological activities in the gaming industry can
influence innovation leading to the development of the whole region (Stolarick et
al. 2006). IP Box tax regime has the advantage that the entities benefiting from
it have already succeeded in their R&D process. It means that the solutions they
have developed were already patented and commercialised. Examining the gaming companies benefiting from IP Box allows checking the trends observed within
efficient and successful entities whose creativity is already successfully monetised. Because the literature review in Section 4 shows that empirical evidence and
theoretical expectations give no clear picture of how the various factors influence
the relationship between firm size and growth, we aim to check if Gibraťs law
holds in the gaming industry. Therefore this paper analyses the impact of IP Box
on the computer games sector growth.
The research includes three perspectives: international, national and regional,
concerning the Wielkopolskie voivodeship. Six hundred seventy-three gaming
companies from 11 countries were analysed, including 68 Polish and 28 companies from Wielkopolska. The data covers the period from 2010 to 2019 for the
global analysis and from 2008 to 2021 for one country’s study. We tested whether Gibrath’s law, which says that the growth of an enterprise is independent of
its size, applies to the computer games sector. The analysis was carried out by
estimating the dynamic panel models using the Arellano-Bover/Blundell-Bond
estimator of the system GMM method, the Arellano-Bond estimator of the GMM,
fixed-effects panel data estimation and OLS. All the models’ estimates aim to
check whether the IP Box affects the firm growth; this is an increase in revenues
from sales in the analysed companies. We paid particular attention to the relationship between IP Box and companies’ growth in Poland and Wielkopolskie
voivodeship. Moreover, we have checked whether companies from Wielkopolska
are developing faster than the companies in Poland.
The paper is structured as follows. Section 2 describes the gaming sector.
Next, Section 3 takes a closer look at the subject of the IP Box regime. Section 4
covers the literature review and develops hypotheses. In Section 5, we describe
the data used and the research design. We present our results in Section 6 and
conclude in Section 7.
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Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
Gaming sector
The game development process can last for years because this sector is characterised by cyclical seasonality of several years (ca. eight years). We can differentiate 7
phases of the game development process, including (1) planning, (2) pre-production, (3) production, (4) testing, (5) pre-launch, (6) launch, and (7) post-production (Pickell 2019). The way how the game is developed forces high investment
and expenses in between short periods when the revenues of the company are
high (new release). This is a typical business model in this sector; however, the
producers operate in a subscription or frequently realised games’ add-ons system.
The data prove that the gaming sector is constantly growing. Mainly online
games are getting more and more popular. PwC’s Global Entertainment & Media
Outlook 2020–2024 Report shows the estimated annual growth rate (CAGR)
between 3.9% and 11% from 2019 to 2024 in the gaming sector among the 11
analysed countries. Our research sample covers the primary European markets
with the highest comparable to Poland gaming industry sales (Germany, the UK,
France, Italy, Spain, Poland, Belgium, and the Czech Republic). Moreover, it includes all three countries where software intellectual property rights are protected (Japan, South Korea, and the USA). Furthermore, Newzoo (2020) highlights
that these countries generate the highest revenue globally. Figure 1 shows the
revenues of the gaming sector in each of the studied countries in 2020.
Czechia
212
Belgium
454
Poland
687
Spain
2 656
Italy
2 661
France
3 987
United Kingdom
5 511
Germany
5 965
South Korea
6 564
Japan
18 683
United States
36 921
0
5 000
10 000
15 000
20 000
25 000
30 000
35 000
40 000
Fig. 1. The revenues in the gaming sector in 2020 (USD M)
Source: own elaboration based on Newzoo Top 10 Countries/Markets by Game Revenues (2020).
According to The game industry of Poland – Report 2021 issued by the Polish
Agency of Enterprise Development (PARP) in August 2021, there were around
470 active game producers and publishers in Poland. The sector’s revenue in
2020 amounted to EUR 969 M. It is estimated that the annual number of new
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
307
releases is higher than 600 games (PARP 2021, p. 7). In this article, we do consider the game industry as a set of game-producing and developing companies.
The data show that such companies in Poland generate almost 96% of their revenues from export. However, we can also differentiate the Polish game market,
dominated chiefly by foreign game titles imported to the country. The report
states that Poland’s total employment in the game industry amounts to 12,110
workers (25% of them are women). It is estimated that the employment growth
rate is 24% YoY (PARP 2021, p. 8). Regarding sales revenues, the YoY growth of
the industry equals nearly 30% (between 2016–2019) and even further accelerated in 2020. Among companies listed on the Warsaw Stock Exchange, 73% have
reported an increase in revenues in 2020 (PARP 2021, p. 10). The biggest Polish
gaming producer is CD Projekt Red S.A, and this company reported revenues that
amounted to almost half of the yearly revenues of the whole sector (e.g. in 2016
and 2020).
Many Polish game producers make efforts to take over the longest possible
fragment of the game development cycle to have as much control over the process
as possible and, at the same time, derive the greatest potential profit from the
production of games. However, it must be clearly indicated that no company in
Poland would succeed while doing it all alone. Even CD Projekt, which, thanks to
the GOG.com store, part of the sale to the end customer is carried out internally,
must collaborate with international digital distribution stores (e.g. steam) (KPT
2020, p. 39).
Wielkopolskie voivodship (north-western region of Poland) is divided into
four cities with poviat rights, 31 poviats and 226 communes, with the seat of
local government authorities in the city of Poznań. In 2020 it was inhabited by
about 3.5 million people (GUS 2020). Wielkopolskie is the second voivodeship in
the country in terms of area and third in terms of population. In 2022 37 gaming
companies were operating in this region (Polski GameDev 2022). These companies produce all types of games, including PCs, mobile web browsers, consoles
and VR games. Wielkopolska, as well as other Polish Regions, have dedicated IT/
ICT clusters established to connect and cooperate with local authorities, scientific and research units and business representatives to popularize and develop
initiatives based on modern ICT technologies (e.g. Wielkopolski Klaster Teleinformatyczny, Klaster Wzgórza Nowych Technologii – Nt Hills, Klaster Firm Informatycznych ICT Pomorze Zachodnie, Multiklaster – Stowarzyszenie Klaster Multimediów i Systemów Informacyjnych or Alternatywny Klaster Informatyczny)
(Klaster IT 2022). In creative sectors such as gaming – clusters can play a vital
role. Research on US video game clusters showed that the factors contributing
to developing them and entrepreneurship in the gaming sector are the following:
concentration of human creativity in arts and technology in a strict localisation,
cross-fertilisation of industries and public policy (Pillon, Tremblay 2013).
Clusters of companies contribute to the formation of technological spillovers
that lead to innovations, which impact the development of the entire region,
which cooperates with each other in a given field in our gaming sector (Stolarick
et al. 2006).
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Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
IP Box regime
IP Box tax regime allows reducing the tax rate subject to the income from intellectual property rights (Evers et al. 2015, Merrill 2016). This tax regime is called
a back-end preference, meaning that companies benefit from it at the end of their
R&D process cycle (successful commercialisation of the developed innovative results is needed) (Lester 2021). It is crucial to note that the IP Box regime should
be constructed in line with the Modified Nexus Approach proposed by OECD
within BEPS (Base Erosion and Profit Shifting) rules (OECD 2015). Therefore, it
is necessary to avoid unfair tax competition between countries.
Considering the introduction of the IP Box in the USA, it was noted that
the region with the higher patent growth also had a higher job growth rate.
Implementing IP Box would encourage manufacturing companies to return to
the country and conduct their operations in the local market (Knight, Maragani
2013). They pointed out, however, that the R&D activities leading to obtaining
patents should be done in-country to allow the US to benefit from introducing
the IP Box regime. According to Caramina (2022), the Italian IP Box regime system was initially aimed to attract companies to retain in the country and relocate
to Italy their activities connected with the development of intangible assets. Due
to the construction of the Nexus ratio, the IP Box regime in Poland also prefers
internal R&D activity leading to developing the qualified IP right. The taxpayer
could purchase only the partial results of R&D works on the market; it is impossible to benefit from IP Box while only purchasing the complete solution subject
to IP protection.
Nevertheless, governments can decide on the type of intellectual property income subject to the IP Box tax rate. They choose between patents, trademarks,
software innovations etc. – catalogue proposed by OECD. However, software
(computer programs) is subject to intellectual protection only in very few countries. Of the 11 analysed countries, Japan, the USA, South Korea, the Czech Republic, and Germany have not introduced the IP Box regime. In the first three
non-European countries, software patent protection is allowed by law. However,
it is crucial to mark that in Europe, the software is not patentable. The preferential tax rate varies from 4.44% to nearly 14% of IP-related income in the
European countries we analyse. For example, implementing the Innovation Box
in Belgium decreased the marginal effective tax rate of 1.88% on marginal R&D
investments (Evers et al. 2015), and the effective tax rate decreased by 7.2%
to 7.9% when developing intellectual property (Bornemann et al. 2020). Still,
MNEs receive more tax benefits from the IP Box than domestic companies. The
summary of the IP Box rate in the analysed countries that have introduced the regime is presented in Table 1. In Poland IP Box tax regime has been in force since
January 2019; under this regulation, the reduced tax rate equals 5%. Qualified IP
rights in Poland include: (1) patent; (2) protection right for a utility model; (3)
the right to register an industrial design; (4) right in registration of integrated
circuit topography; (5) additional protection right for a patent for a medicinal
product or a plant protection product; (6) the right to register a medicinal prod-
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
309
Table 1. IP Box in European Countries
Country
IP Qualifying Assets
Year
IP Box (%)
Statutory tax
rate (%)
Patents
Software
France
Belgium
Spain
UK
Italy
2000
2007
2008
2013
2015
x
x
x
x
x
x
x
x
–
x
10
4.44
10
10
13.95
28
29
25
19
24
Poland
2019
x
x
5
19
Source: OECD Dataset Intellectual Property Regimes (2019); Tax Foundation Report: Patent Box
Regimes in Europe (2020); KPMG Corporate Tax Rate (2021).
uct and an authorised veterinary medicinal product admitted to trading; (7) the
exclusive right referred to in the Act of June 26, 2003, on the legal protection of
plant varieties; and (7) copyright to a computer program.
The income subject to the IP Box tax rate is obtained from qualified IP (in line
with the IP Box tax regulations) and multiplied by the Nexus formula (defined
in the PIT and CIT Acts). In Poland, companies from the IT sector are highly interested in IP Box taxation due to the last qualified IP right category – copyright
to the computer program. In 2019, there were 1,924 IP Box taxpayers, and the
amount of IP tax paid by them accounts for PLN 46 million (the average tax paid
is PLN ca. 24,000 per taxpayer). Comparing this data with the content of the individual tax rulings issued by the Polish tax Authorities, we may suppose that the
vast majority of taxpayers using IP Box come from the IT sector. Table 2 shows
Table 2. IP Box taxpayers and the tax paid (PLN M) in Poland (2019–2020)
CIT IP Box taxpayers
Year
Number
total tax paid
(in millions PLN)
PIT IP Box taxpayers
Number
total tax paid
(in millions PLN)
2019
65
24
1 859
22
2020
104
55
4 520
54
Source: own elaboration based on data from the Ministry of Finance of Poland.
Table 3. Number of active protection rights in Poland in 2019 and 2020
2019
2020
Patents for inventions
Number of protection rights
18,336
18,731
European patents
73,638
83,800
Protection rights for a utility model
3,623
3,931
Rights from registration of industrial design
8,368
8,500
Additional protection rights for medicinal products and plant
protection products
234
287
Integrated circuits topography
47
49
Source: own elaboration based on the Annual Reports of the Patent Office of the Republic of Poland
issued in 2019 and 2020.
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Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
the data concerning the popularity of IP Box in Poland between 2019 and 2020
among PIT and CIT taxpayers.
However, the potential of the IP Box regime in Poland is much higher, which
is proved by the data from the Polish Patent Office presented in Table 3.
Hypothesis development
Gibrat’s law of proportionate effect predicts that firm growth is independent
of its size (Gibrat 1931). Most models defining firm size changes assume Gibrat’s law of proportional change. In its simplest form, Gibrat’s law states that
the probability distributions of the growth rate of a firm’s size are independent
random variables with the same distribution (Kwaśnicki 2004, p. 2). However,
there is research which argues with Gibrat’s law. It has been proved that smaller
firms are characterised by higher growth rates than larger firms (Audretsch et al.
1999). This is especially visible for innovative companies (Calvo 2006).
On the contrary, considering that economics of scale affect the production
process, large firms should have an advantage and grow faster than small firms.
On the other hand, Audretsch and Elston (2010) proved the positive correlation
between a company’s size and growth rate (cross-industry study in Germany).
It suggests that Gibrat’s law should be more likely to hold in the innovative
sectors. In addition, it is worth notice that multi-plant companies tend to have
greater financial backing than single-plant firms, which can positively influence
their growth rates (Geroski, Gugler 2004, Fagiolo, Luzzi 2006). The research also
confirmed the positive impact of clustering and knowledge spillovers on companies’ growth rates (Park et al. 2010).
Since the empirical evidence and theoretical expectations provided above give
no clear picture of how the various factors influence the relationship between
firm size and growth, we aim to check if Gibraťs law holds in the gaming industry.
Our research is the first that analyses this issue in the gaming industry, characterised by no liquidity constraints, high competitiveness in the digital economy and
various access to the IP Box advantages. We state the hypothesis:
H1: Gaming company growth is independent of its size.
This article also aims to examine whether Innovation Box regimes are efficient in supporting the growth of gaming companies, particularly in the Polish
market. Tax incentives tend to support companies by increasing the money (free
cash flows) that can be reinvested in line with the companies’ needs. A lower IP
Box tax rate, being a back-end solution, helps gain higher sales revenues from
the commercialisation of innovative solutions and therefore enables higher R&D
investments in the future. According to the literature, corporate productivity
growth positively correlates with R&D expenditures (Minasian 1962, 1969). The
value added for the company increases when the innovation process is successfully finished.
On the other hand, regarding R&D expenditures, they include both the positive and negative results of conducted R&D activity. R&D returns are very high,
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
311
even hundreds to thousands per cent. Their development bounded with the increased productivity caused by R&D activity may result in lower prices. This
change will affect companies’ sales revenues (Minasian 1969).
Moving strictly to the gaming sector, the extra money they obtain via the IP
Box tax rate can be used to positively influence the production capacity or revenue growth of existing products that have entered the market. However, the
efficiency of IP Box depends on the companies’ decision on how to spend the
extra money. For example, this tax incentive may become inefficient if used for
payouts such as dividends or higher salaries. To find out what are the results of
introducing IP Box in the gaming sector, we have stated the following hypothesis:
H2: IP Box positively influences the revenue growth rate of gaming companies.
And to strictly discover how the situation looks like in the Wielkopolskie
voivodeship, we added hypothesis no. 3, which allows comparing this region to
the rest of the country.
H3: The companies from the gaming sector in Wielkopolskie voivodeship grow faster
than the gaming companies from other regions of Poland.
Research design
Our research sample covers the international gaming market of leading European
countries (Belgium, Czech Republic, France, Germany, Italy, Poland, Spain and
the UK), Japan, South Korea, and the USA. We use financial, employment and
ownership data from 2011 to 2019 retrieved from the Orbis database and KPMG
Reports for international study and from 2008 to 2021 for the regional research
dedicated to Poland. Five analysed countries (Czech Republic, Germany, Japan,
South Korea, and the USA) did not introduce the IP Box regulations. South Korea and the USA have tax regulations concerning R&D and intellectual property
activities, but it is crucial to mention that they differ significantly from the European IP Box tax regimes. Table 4 presents definitions of variables.
Table 4. Definitions of variables
Variable
Definition
Dependent variables:
Revenue_Growth
Ln_Sales
ln(Revenuet) – ln(Revenuet–1)
ln(Salest)
Test variables:
Lagged dependent
variable
ln(Salest–8)
Revenue_Growtht–1
IP_BOX
A binary variable indicating when IP Box has been implemented equals 1 –
for the year of introducing IP Box and after, and 0 – otherwise
Wielkopolska
Binary variable indicating when the company is located in Wielkopolska
voivodeship equals 1, and 0 – otherwise
Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
312
Variable
Definition
Did
Interaction of IP_BOX time dummy variable and Wielkopolska binary
variable
Control variables:
Tangible xed assets
Total assets
Capital intensity
Intangible xed assets
Total assets
Intangibility
Inventory
Current assets
Total assets
Leverage
Long-term debt
Total assets
Size
ln (Total Assets)
MNE
Binary variable indicating if a firm has foreign shareholders that equals 1 –
if the firm’s foreign shareholders have more than 50% share in equity, and
0 – otherwise
Prot (Loss) before interest and tax
Total assets
ROA
Employees
ln (Number of employees)
STR
Statutory Tax Rate
Kaufmann
Average of six sub-index of the Worldwide Governance Indicators that rank
countries concerning six aspects of good governance: Voice and Accountability, Political Stability and Violence, Government Effectiveness, Rule of Law,
and Control of Corruption.
Ownership
Categorical variable indicating the type of ownership structure that consists
of 15 levels: Bank; Corporate; Hedge fund; Employees, managers, directors;
Financial company; Private equity firms; Public (listed companies); Venture
capital; Insurance company; Foundation; Research Institute; Self-ownership;
One or more named individuals or families; Other unnamed shareholders
aggregated, Mutual and pension fund nominee trust trustee; Public authority
state government
Source: own elaboration.
To check in H1 if Gibrat’s law holds for the gaming industry in international institutional settings, we estimate the following model using ordinary leastsquares (OLS).
Salesi,t = β0 + β1IP_BOXc,t + β2Salesi,t–8 + β3Controlsi,t + β4Controlsc,t + εi,t
(1)
The subscripts i, c and t denote firm, country, and year.
To address the H2 hypothesis, whether IP Box regimes are associated with
the growth of companies in the gaming sector, we estimate models in eq. (2)
where revenue growth captures incremental changes in value. In addition, we
control Size, Leverage, Employees, Intangibility, Capital Intensity, Inventory, MNE, and
ownership structure on a firm level and STR, Patents, and Kaufmann on a country
level. The company’s size (Size) assumes that larger firms that produce on a large
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
313
scale are likely to have more innovative activity and benefit from economies of
scale. However, Leverage is used to address the financial constraints of companies
(Balsmeier et al. 2017, Hall et al. 2007), but also the opportunity to decrease the
cost of capital in the case of public (listed) companies.
Revenue_Growthi,t = β0+ β1IP_B0Xc,t + β3Controlsi,t + β4Controlsc,t+ εi,t
(2)
Models described by eq. (2) are estimated at the firm-country-year level using
Arellano-Bond GMM (Arellano, Bond 1991) and fixed-effects (FE) panel data
analysis estimators. Finally, models in eq. (3) and (4) are estimated using the
two steps Blundell-Bond system GMM estimator dedicated to dynamic panel data
(Blundell, Bond 1998) for the Polish subsample.
Revenue_Growthi,t = β1IP_B0Xi,t + β2Wielkopolskai,t + β3didi,t+ β4Controlsi,t +
β5time_dummyi,t+ β6yeari,t+ υi + εi,t
(3)
ln_Salesi,t = β1IP_B0Xi,t + β2Wielkopolskai,t + β3didi,t+ β4Controlsi,t +
β5time_dummyi,t+ β6yeari,t+ υi + εi,t
(4)
where: βi – parameter, i – observation number, t – subsequent year, υi – panel-level
effects, εit – independent and identically distributed effects.
Results
Based on Gibrat’s equation estimation outcomes using the OLS approach provided in Table 5, we conclude that in the gaming industry, over the period 2012–
Table 5. Effect of IP Box on firm’s growth – Gibrat’s equation
Sales in 2012 H1
IP_BOX H2
MNE
Capital_Intensity
Intangibility
(1)
OLS
Sales
(2)
OLS
Sales
(3)
OLS
Sales
(4)
OLS
Sales
(5)
OLS
Sales
(6)
OLS
Sales
0.9787***
(0.0189)
–0.392***
(0.1317)
0.0998
(0.1410)
0.0642
(0.3244)
0.0732
0.9080***
(0.0249)
–1.617***
(0.3435)
0.1238
(0.1392)
0.1827
(0.3214)
–0.02016
0.9813***
(0.0189)
–0.430***
(0.1351)
0.2062
(0.1457)
–0.1331
(0.3351)
0.01961
0.9066***
(0.0245)
–1.716***
(0.3411)
0.2332
(0.1424)
0.09471
(0.3287)
–0.07036
0.9751***
(0.0085)
0.0541
(0.0795)
0.1155
(0.0846)
–0.0041
(0.0206)
–0.1264
0.9601***
(0.0099)
–0.554***
(0.2084)
0.1324
(0.0854)
–0.0008
(0.0205)
–0.1137
(0.2121)
(0.2111)
(0.2191)
(0.2159)
(0.1194)
(0.1203)
Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
314
Inventory
Employees
Leverage
Size
STR
Kaufmann
Patents
Ownership_Effects
Corporate
State-owned
enterprises
Bank
(1)
OLS
Sales
(2)
OLS
Sales
(3)
OLS
Sales
(4)
OLS
Sales
(5)
OLS
Sales
(6)
OLS
Sales
0.00002
(0.00002)
0.0172
(0.0401)
–0.2501
(0.2240)
0.0501
(0.0315)
2.435**
(1.1990)
–0.4425**
(0.1814)
–0.5606
(0.4233)
YES
0.00001
(0.00002)
0.00094
(0.0431)
–0.4242*
(0.2243)
0.1317***
(0.0366)
-8.5460
(0.1816)
1.046
(3.222)
–1.208**
(0.6067)
YES
0.00002
(0.00002)
0.00409
(0.04165)
–0.2348
(0.2314)
0.06022*
(0.03253)
2.222*
(1.242)
–0.510***
(0.1884)
–0.4476
(0.4413)
YES
0.00001
(0.00002)
0.005024
(0.04418)
–0.4254*
(0.2293)
0.1481***
(0.03731)
4.974
(0.1865)
–1.569
(3.305)
–0.7716
(0.6179)
YES
–0.3726*
(0.2060)
0.7364***
(0.2676)
–0,4297**
(0.2113)
0.6573**
(0.2641)
–0.576***
(0.2128)
0.6051**
(0.2767)
0.00001
(0.00002)
0.03131
(0.0215)
–0.2013
(0.1444)
0.0228**
(0.0112)
6.018
(0.1238)
–1.267
(2.206)
–0.4671
(0.3894)
YES
0.2226***
(0.0646)
0.5912***
(0.1972)
0.3285*
(0.1717)
–0.4361**
(0.2163)
–0.4589**
(0.2140)
0.00002
(0.00002)
0.0189
(0.0202)
–0.1723
(0.1416)
0.01443
(0.0107)
2.445
(0.6708)
–0.465***
(0.1173)
0.0297
(0.2484)
YES
0.2308***
(0.0633)
0.6393***
(0.1976)
0.3906**
(0.1699)
0.3511*
(0.2006)
–0.2726*
(0.1494)
–0.3211**
(0.1538)
0.5855***
(0.1713)
NO
670
0.9864
1394***
1.919
(0.15)
0.5456***
(0.1739)
YES
670
0.9864
1394***
1.919
(0.15)
83.88***
83.88***
Insurance_company
Self_ownership
CountryxKaufmann
No. of observations
R2
F-statistic
RESET test
(p-value)
0.9356***
(0.2522)
NO
317
0.9766
341.3***
6.2149
(0.002)
0.7670***
(0.2527)
YES
317
0.9791
305.4***
9.669
(0.000)
1.249***
(0.2602)
NO
317
0.9795
391.9***
1.909
(0.15)
0.1890*
(0.1031)
0.9873***
(0.2588)
YES
317
0.9821
357.9***
3.613
(0.03)
Breusch-Pagan test
39.866*
46.69*
44.59**
47.23*
Family firms
individuals
Unnamed
shareholders
Note: p < 0.01; p < 0.05; p < 0.1
Source: own elaboration.
***
**
*
2019, revenue in small firms has grown more than in others. Therefore, all the
models in Table 5 considered reject Gibrat’s law. However, larger companies with
higher assets (size variable) generate greater revenue. We also provide substantial evidence that IP Boxes didn’t support revenue growth in the gaming industry.
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
315
These reject H2. More revenue is generated in countries with higher statutory tax
rates and less governance quality, primarily by public companies with unnamed
shareholders (substantial free float) or owned by banks.
Table 6 delivers the outcomes of testing hypothesis H2 using GMM dynamic
panel data model (columns 1–3) and fixed-effects (FE) estimator (columns 4–5)
for a narrower sample due to ETR restrictions. It provides evidence that implementing the Intellectual Property Box Regime negatively affects a gaming firm’s
revenue growth.
Table 6. Effect of IP Box on firm’s growth
IP_BOX H2
L.Revenue_Growth
H1
(1)
GMM
(2)
GMM
(3)
GMM
(4)
FE
(5)
FE
Revenue_
Growth
Revenue_
Growth
Revenue_
Growth
Revenue_
Growth
Revenue_
Growth
–0.3424**
(0.1394)
0.0232
(0.0762)
–0.3032**
(0.1373)
0.0312
(0.0710)
–0.2723*
(0.1653)
0.1155*
(0.0624)
–0.0980*
(0.0526)
–0.1103*
(0.0576)
0.0059***
(0.0016)
–0.1915**
(0.0949)
0.0011***
(0.0003)
0.0059***
(0.0016)
–0.1865*
(0.0966)
0.0010***
(0.0002)
–0.2659
(0.2103)
–0.00004***
(0.00001)
–0.2348
(0.2065)
–0.0001***
(0.00001)
–0.1336**
(0.0531)
–0.1507
(0.1726)
–0.1295**
(0.0536)
–0.1375
(0.1748)
0.1952***
(0.0468)
–0.3757
(0.4135)
–0.1733
(0.2334)
0.2376**
(0.1140)
0.1892***
(0.0454)
–0.3333
(0.5654)
0.1987
(0.3127)
0.3508**
(0.1607)
ROA
MNE
Capital_Intensity
L.Capital_Intensity
Intangibility
Inventory
L.Inventory
Employees
Leverage
L.Leverage
Size
STR
Kaufmann
Patents
–0.0659
(0.0806)
0.3526
(0.5561)
0.1356
(0.5902)
–0.0298
(0.4276)
–0.0003***
(0.00002)
0.00006***
(0.00002)
0.00262
(0.0876)
–0.1332
(0.2007)
0.1930
(0.1737)
0.2859**
(0.1204)
–0.6509
(1.0652)
–0.5338
(0.3821)
0.19997
(0.211)
–0.0583
(0.0782)
0.3300
(0.5601)
0.0957
(0.5908)
–0.0227
(0.4209)
–0.0003***
(0.00002)
0.00006***
(0.00002)
0.01953
(0.0860)
–0.1192
(0.1996)
0.2213
(0.1792)
0.2828**
(0.1204)
–0.3057
(1.2359)
0.3523
(0.2465)
–0.2110
(0.1437)
0.0618***
(0.0152)
0.0038
(0.0044)
–0.2895
(0.2051)
–0.0003***
(0.00003)
0.00004
(0.00003)
0.1176
(0.0720)
–0.0295
(0.1782)
0.2265*
(0.1302)
0.1580***
(0.0324)
–1.6550
(1.2741)
–0.12896
(0.3366)
–0.0105
(0.3185)
316
Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
Ownership_Effects
Corporate
State-owned
enterprises
(1)
GMM
(2)
GMM
(3)
GMM
(4)
FE
(5)
FE
Revenue_
Growth
Revenue_
Growth
Revenue_
Growth
Revenue_
Growth
Revenue_
Growth
YES
–0.1072*
(0.0635)
0.2541*
(0.1471)
YES
–0.1192*
(0.0616)
0.2601*
(0.1480)
–0.1235*
YES
YES
YES
–0.0718
(0.0437)
0.1063*
(0.0608)
–0.0814*
(0.0468)
0.1448**
(0.0619)
NO
YES
Financial_company
(0.0735)
Foundation_
research institute
Self_ownership
Country x
Kaufmann Effects
Time Effects
Number of
observations
Number of groups
R2
F-statistic
Hausman test
Breusch-Pagan test
Sargan test
Arellano-Bond
AR(2)
Wald test
Wald test for time
dummies
NO
YES
NO
YES
YES
YES
1 380
1 380
4 038
2 261
2 261
360
360
673
360
8%
6.11***
146.97***
798.94***
360
10%
4.85***
114.37***
1282.8***
6.412 (0.27)
0.541 (0.59)
5.738 (0.33)
0.455 (0.65)
6.873 (0.23)
–2.190 (0.03)
1683.58***
1955.09***
388.87***
13.668**
11.237*
16.781**
Note: ***p < 0.01; **p < 0.05; *p < 0.1
Source: own elaboration.
Firms with higher ROA, capital intensity and size have a significantly higher
growth rate in the FE models (4)–(5), particularly in more patenting countries. Although gaming companies reduce their tax rate and tax liabilities thanks to IP Box,
the tax savings and free cash flows require time to materialise and increase their
growth compared to their competitors from the countries with the highest revenue
in the gaming industry. However, the parameter at the IP Box variable is significant
and negative in all models in Table 6. It is caused at least partly by higher inventory
that is increased by unsold games. Thus, we reject the H2 hypothesis. Although the
total number of patent applications (Patents) at a country level positively influences
revenue growth in FE models, their impact diminishes in GMM models.
Tables 7 and 8 focus on the Polish subsample. Based on the negative coefficient at the lagged Revenue_growth variable, we conclude that the small firms are
growing faster than the big companies. So, Gibrat’s law in the gaming sector in
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
317
Poland is not binding. Although IP Box negatively influences the revenue growth
of gaming companies in Poland, its interaction with the Wielkopolskie voivodeship variable positively impacts their growth in the Wielkopolska region. Models (1)–(2) show that the companies from the Wielkopolskie voivodeship grow
faster than in the rest of Poland. This gives us no basis to reject hypothesis H3.
Considering dynamic effects, capital intensity, intangibility, and inventory limit
the revenue’s growth. Only revenues of firms with larger assets described by the
Size variable grow faster than others.
Table 7. Effect of IP Box on firm’s growth in Poland – system GMM
L1.Revenue_Growth
H1
IP_BOX
H2
Wielkopolska
H3
did (Wielkopolska x
IP_BOX)
L1.did
Capital_intensity
L1.Capital_intensity
Intangibility
L1.Intangibility
Inventory
L1.Inventory
Leverage
L1.Leverage
Size
year 2010
year 2011
(1)
system GMM
Revenue_Growth
–0.0468
***
(0.0078)
1.2647
(0.3615)
***
(2)
system GMM
Revenue_Growth
–0.0468
***
(0.0078)
–0.7004
***
(0.1173)
1.2647
***
(0.3615)
H2
(3)
system GMM
Revenue_Growth
–0.0491
***
(0.0084)
–0.9972
***
(0.1382)
1.0179
(0.4018)
0.8087
**
(0.3400)
H2
5.2769
(0.7934)
–12.6313
(1.0054)
2.9744
(0.8542)
–9.3360
(1.3513)
4.5580
(0.4948)
–10.1250
(0.4830)
0.6402
(0.8879)
–0.8850
(1.5045)
0.5486
(0.0349)
1.7519
(0.3661)
0.8922
(0.9801)
***
***
***
***
***
***
***
***
5.2769
(0.7934)
–12.6313
(1.0054)
2.9744
(0.8542)
–9.3360
(1.3513)
4.5580
(0.4948)
–10.1250
(0.4830)
0.6402
(0.8879)
–0.8850
(1.5045)
0.5486
(0.0349)
0.6580
(0.3833)
–0.2022
(0.9656)
***
***
***
***
***
***
***
*
–0.7709
(0.3425)
**
4.9234
***
(1.0147)
–13.5034
(0.7277)
2.8281
(0.8664)
–9.1146
(1.2939)
4.5061
(0.4651)
–9.8641
(0.4745)
0.6329
(0.8080)
–1.9206
(1.3963)
0.5463
(0.0359)
0.8184
(0.3759)
–0.6350
(1.0233)
***
***
***
***
***
***
**
Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
318
(1)
system GMM
Revenue_Growth
0.3804
(1.9309)
2.2665
***
(0.1832)
(2)
system GMM
Revenue_Growth
–0.7146
(1.9150)
1.1710
***
(0.2227)
(3)
system GMM
Revenue_Growth
–1.7059
(2.0703)
1.1885
***
(0.2115)
year 2014
2.3666
(0.1762)
***
1.2706
(0.2037)
***
1.3248
(0.2146)
***
year 2015
1.7076
(0.1477)
***
0.6110
(0.1778)
***
0.6523
(0.1928)
***
year 2016
1.8253
(0.1904)
1.1450
(0.1712)
1.0982
(0.1781)
0.3983
(0.1812)
***
0.7282
(0.1771)
0.0473
(0.1318)
***
0.7708
(0.1600)
0.1147
(0.1400)
***
–0.3989
(0.1812)
–1.2341
(0.2386)
–0.0004
(0.0001)
816
68
97
41.7611
0.9991
**
0.0216
(0.1932)
–0.7959
(0.2869)
–0.0004
(0.0002)
816
68
99
41.1913
0.9993
year 2012
year 2013
year 2017
year 2018
year 2019
***
***
**
year 2020
year 2021
–0.8347
(0.2611)
–0.0010
(0.0001)
816
68
97
41.7611
0.9991
year
Number of observ
Number of groups
Number of instr
Sargan test
***
***
***
***
***
**
Arellano-Bond test for zero autocorrelation in first-differenced errors
AR(1)
AR(2)
–3.1976
0.0014
1.5033
–3.1976
0.0014
1.5033
–3.3172
0.0009
0.98368
0.1328
0.1328
0.3253
Note: p < 0.01; p < 0.05; p < 0.1
Source: own elaboration.
***
**
*
In Table 8, models (1)–(2) estimates show significant positive, lower than
one, estimates of a parameter at the lagged sales variables, indicating that the
smaller companies generate higher sales. Therefore, we reject the hypothesis of
Gibrat’s law (H1). The coefficient at the lagged IP Box variable in model (2) is
significantly negative, showing that IP Box does not increase sales growth in
gaming companies. Again, we reject H2. Although IP Box, a back-end preference,
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
319
generates profits for the companies when they start commercialising developed
innovative solutions, the negative correlation may be a matter of the gaming sector or too short a time frame of data availability. A significant negative parameter
at the Wielkopolska variable shows that companies from Wielkopolskie voivodeship sell less than the other Polish companies. Companies with higher assets,
capital intensity, intangibility and inventory but less indebted in the previous
period sell more.
Table 8. Effect of IP Box on firm’s growth – Gibrat’s equation for Polish subsample
(1)
(2)
OLS Sales
L1.ln_Sales_
H1
L8.ln_Sales_
H1
L9.ln_Sales_
L1.IP_BOX
H2
Wielkopolska
H3
Capital_intensity
L1.Capital_intensity
Intangibility
L1.Intangibility
Inventory
L1.Inventory
Leverage
L1.Leverage
Size
**
6.2086
(2.3507)
1,2288
**
(1.3422)
2.3061
(0.7909)
–0.3549
(0.6630)
2.8278
(0.5687)
–0.7733
(0.5002)
–1.3244
(1.5549)
–2.9842
(0.9805)
0.7819
(0.0407)
year 2016
year 2017
year 2018
OLS Sales
0.0803
(0.0374)
0.0256
(0.0095)
–0.0314
(0.0130)
–0.0814
(0.1131)
–0.6204
(0.3758)
–0.0882
(0.0974)
–0.0576
(0.0812)
**
0.0841
(0.0379)
0.0304
(0.0076)
**
***
**
*
***
***
***
***
–0.2716
(0.1271)
–0.6736
(0.4416)
5.6151
(0.7826)
0.6509
(0.7169)
3.2355
(0.5826)
–0.4266
(0.5760)
3.3670
(0.4500)
–0.6464
(0.5763)
0.1805
(1.3500)
–2.2577
(0.7984)
0.7163
(0.0315)
0.1565
(0.0718)
–0.0638
(0.0718)
–0.1032
(0.0708)
**
##
***
***
***
***
***
**
Agnieszka Teterycz, Anna Białek-Jaworska, Michał Woźniak, Monika Piosik
320
year 2021
year
Number of observations
Number of groups
Number of instruments
Sargan test
(1)
(2)
OLS Sales
OLS Sales
0.0354
(0.0912)
0.0001
(0.0002)
340
68
60
36.3618
0.7161
0.1169
(0.0904)
0.0002
(0.0002)
408
68
70
37.9181
0.9282
Arellano-Bond test for zero autocorrelation in first-differenced errors
AR(1)
AR(2)
–1.7176
0.0859
1.1424
–2.0107
0.0444
–0.5074
0.2533
0.6118
Note: p < 0.01; p < 0.05; p < 0.1;
Source: own elaboration.
***
**
*
##
p < 0.15
Conclusion
This article analyses the development of the gaming sector from international,
domestic and regional perspectives, focusing on the Wielkopolskie Voivodeship,
showing the impact of the lower IP Box tax rate on the company’s growth. Our
study provides evidence that Gibrath’s law is not binding in the gaming sector. It
does not matter whether we consider the growth’s dependence on the firm size
from a multinational, Polish or regional (Wielkopolska voivodeship) perspective.
Instead, our results confirm that small gaming producers and developers are
growing faster than their larger rivals. Our findings are in line with Audretsch
et al. (1999) and Calvo (2006 ) but contrary to Audretsch and Elston (2010),
Geroski and Gugler (2004) and Fagiolo and Luzzi (2006). Our outcomes probably are due to more flexibility and less risk in developing games when supported
by institutional owners, including banks, insurers and unnamed shareholders in
the case of joint stock companies listed on the stock exchange. Unfortunately,
we did not find evidence that IP Box supports the firm’s growth except for the
Wielkopolska region. However, gaming firms set in Wielkopolskie voivodeship
sell less than their Polish competitors; therefore, it seems easier to boost revenue
growth in this case. Our results align with Gaessler et al. (2021) but are opposite
to Bradley et al. (2015), Evers et al. (2015), Mohnen et al. (2017), Chen et al.
(2019), Haufler and Schindler (2020). It is due to gaming firms’ business model
that offers extraordinary growth in preordering and the first year of sale of the
new game, IP Box’s effects require time to influence firms’ growth positively.
More chances for these effects are given to firms with more remarkable and dynamic changes in capital intensity, intangibility and inventory.
Do gaming companies benefit from the IP Box tax rate? Multinational, Polish
321
Further research on the effect of IP Box on the gaming sector should consider
the revenue growth of personal income (PIT) taxpayers that benefit from IP Box
and their impact on economic growth in time and cross-regionally. Nevertheless,
in the following years, when the relatively new IP Box legislation will be valid
for 5-6 years, further research could also cover the spillover effects occurring in
the gaming sector and leading to regional development. Future research, adding
to Park et al. (2010), can check how clustering and knowledge spillovers impact
companies’ growth rates.
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Czy spółki sektora gier komputerowych odnoszą korzyści
z IP Box? Perspektywa międzynarodowa, polska i województwa
wielkopolskiego
Zarys treści: Celem artykułu jest weryfikacja wpływu obniżonej stawki podatkowej IP BOX na przychody spółek z branży gier komputerowych oraz prawa Gibrata stwierdzającego, że wzrost firmy jest
niezależny od jej wielkości. Dynamiczne modele panelowe oszacowane metodą GMM, FE dla danych
panelowych i MNK, opracowano na danych 673 spółek z 11 krajów. Wykazano, że małe firmy z branży
gier komputerowych rosną szybciej niż ich więksi rywale. Tym samym odrzucono prawo Gibrata. Nie
potwierdzono, że IP Box wspiera wzrost przedsiębiorstw z wyjątkiem województwa wielkopolskiego.
Większe szanse na korzyści z IP Box (obniżona do 5% stawka podatku dochodowego obowiązująca
w Polsce od 2019 r.) mają firmy o bardziej istotnych i dynamicznych zmianach kapitałochłonności,
aktywów niematerialnych i zapasów. Branża gier wideo w Wielkopolsce odnosi większe korzyści z IP
Box niż w pozostałej części Polski.
Słowa kluczowe: IP Box, sektor gier komputerowych, rozwój przedsiębiorstw