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Discussion Paper

Central Bureau of Statistics, P.B. 8131 Dep, 0033 Oslo 1, Norway

No. 6 1 April 1985

DEPRECIATION PROFILES

AND THE USER COST OF CAPITAL BY

ERIK !HORN

111

ABSTRACT

The standard neo-classical formulae for the user cost of capital is based on the assumption that the retirement and decline in efficiency of the

capital units with age follow an exponentially declining function (exponential decay). In the present paper, we generalize this specification

to the case where the capital volume is defined in terms of a general survival function. The specification of the corporate tax system in this context is discussed. Three capital concepts are involved: the gross capital, the net capital, and the tax accounting capital. Conditions for neutrality of the tax system, which generalize previous results in the literature, are established. Numerical illustrations based on Norwegian data are reported.

Not to be quoted without permission from author(s). Comments welcome.

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DEPRECIATION PROFILES AND THE USER COST OF CAPITAL

CONTENTS

1. Introduction . ▪ • • .... . .. • • • ... • • . • • • • • OOOOO • O • OOOOO • • • • OO • .. .

2. Preliminaries: Gross capital, net capital, replacement

(deterioration) and depreciation O O ... OS OS 4 3. The user cost of capital: A general formula .. .... • .... • ... • 9 4. The effect of the tax system .. . ... ...

... 04 12 5. Numerical illustrations ... ... . ... . . ... ... ... 17 References . 4104416410 ,14.40 ... • S. 000004 00•4100004400 29

Paper presented at the European Meeting of the Econometric Society, Pisa, 29 August - 2 september, 1983. I am grateful to Petter Frenger and Agnar Sandmo for useful comments.

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1. INTRODUCTION

The cost of using real capital as a factor of production is one

of the principal determinants of the firm's investment decisions. It is also a useful tool in theoretical and empirical analysis of the system of corpo- rate taxation. Seminal contributions to this literature were the articles by Jorgenson (1967) and Hall and Jorgenson (1967), in which the user cost of capital and its dependence on the corporate income tax system were inte- grated into a neo-classical model of producer's behaviour. A basic assump- tion in these articles, which has been more or less tacitly accepted by

most researchers, is that the replacement investment (technical d

preciation) is a constant, time invariant proportion of the capital stock.

Constant rate of technical depreciation has also become a main ingredient iii the growing literature on the optimality, or lack of optimality, of the corporate income tax. 1)

Several authors have, however, contested this hypothesis, both theoretically and empirically 2)

If we disregard the empirically un- interesting situation in which investment grows at a constant rate it will be satisfied only in the special case where the survival rates are exponentially3)

declining functions of the capital's age (exponential decay). Jorgenson, on the other hand, has attempted to justify this hypothesis as an approximate long-run description. (Jorgenson et al.

(1963).) He invokes "a fundamental result in renewal theory that replacements for . an infinite [investment] stream approach a constant

1) See e.g. King (1975), Sandmo (1974), Boadway and Bruce (1979), and Atkinson and Stiglitz (1980, section 5.3).

2) Examples are Griliches (1963), Feldstein and Foot (1971), Eisner (1972), Feldstein and Rothschild (1974), and Hulten and Wykoff (1981).

3) When considering time as continuous. If time is discrete, the hypothesis implies geometrically declining survival rates.

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proportion of capital stock for (almost) any distribution of replacements for a single investment and for any initial age distribution of capital stock" (Jorgenson (1963, p. 251).) Long-run constructs are, however, difficult to implement.econometrically, and in any case, the relevance of Jorgenson's simple conclusion for

short

-

term

model building is questionable.

The short-run variations in economic activity are usually accompanied by large fluctuations in gross investment , and it may be a drastic simplifi- cation. to exclude

a priori

the possibility that these fluctuations affect the average annual depreciation rate.

The problem of defining and measuring the user cost of capital is closely related to the problem of defining and measuring the volume of the capital stock. They are, in a sense,

dual

problems: This implies that the underlying specification of the replacement process should be the same for the two variables if they are to be applied in the same analysis. It would, for instance, be inconsistent to combine user cost series conctruc-

ted on the basis of a constant rate of technical depreciation with capital data computed by cumulating previous investment series and assuming linear depreciation or a 'one horse shay' (simultaneous exit) specification; the lat- ter being .a coon procedure for constructing capital data in several

. 4) countries.

Moreover, taking constant rate of technical depreciation as a

maintained hypothesis will strongly restrict the class of tax systems which can be analyze& fram the point of view of optimality (neutrality). Sympto- matically, authors dep iag with this issue have almost without exception considered, only the

declining

baZance

method

of calculating depreciation allowances for tax purposes.5)

This is probably due to the formal

4) See, for instance, OECD (1982).

5) Examples are Sandmo (1974), Hartman (1978), Boadway (1980), and Bergström and Södersten (1982).

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similarity between this depreciation scheme and the specification with a constant rate of technical depreciation, since it implies that a constant fraction of the firm's book value of the capital stock is written off in its accounts each year. But practically important depreciation schemes like

straight-line depreciation and the sum-of -the -years'-digits method, cannot be properly handled within this framework. So both theoretically and empirically the standard parametrization may be felt as something of a strait-jacket, and a generalization is well worth exploring.

In this paper, we attempt to generalize the specification with constant rate of technical depreciation to the situation

where the capital volume is defined in terms of a general survival function on the basis of past investment We start by defining the basic capital concepts (and some related terms) required for deriving the user cost of capital (section 2). It becomes essential to distinguish between the capacity 'dimension' and the wealth 'dimension' of the capital. The former represents the (potential) flow of capital services fram a firm's equipment at a given point of time - it is the variable to be used as argument in a production function. The user cost of capital is the cost per unit of these capital services, or equivalently, the cost of using the capacity of the capital stock at a given point of time. The wealth dimension of the capital, on the other hand, is needed for defining corporate income, depreciation, depreciation allowances for tax purposes, and hence taxable

income.- In section 3, we derive, on the basis of these two capital concepts, a general expression for the user cost of capital in the presence of corpo- rate taxation. In sertion 4, we consider more closely the effect of the tax system on the user cost via the rules for depreciation allowances, interest deductibility, and capital gains taxation. Our results appear as generali- zations of previous conclusions in the literature confined to models with exponential depreciation. Finally, in section 5, we present some numerical results based on parametric survival profiles and Norwegian data.

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4

2. PRELIMINARIES: GROSS CAPITAL, NET CAPITAL, REPLACEMENT (DETERIORATION), AND DEPRECIATION

Let J(t) denote the quantit Y invested by the firmat time t, where time is considered as continuous. To characterize the retirement of the capital units over time, we introduce the function B(s), indicating the proportion of an investment made s years (periods) ago which still exists as productive capital. It represents both the loss in efficiency of existing capital units and physical disappearance of old capital goods.

This function, which we call the

'technical survival function',

is non increasing, with values between 0 and 1

°<B(s)<1, B'(s)<0 (if it exists) for all s>0, B(0)=1, B(°°) =O.

We assume that the units of measurements6) are chosen in such a way that

one capital unit

'0,.,o&tc..res'

one unit of capital services per unit of time.

Then

(2) K(t,) = B(s)J(t—s)

represents both the volume of the capital which is s years of age at time t and the momentaneous flaw of capital services produced at time t by capital of ag, ; . The total capital volume at time t, in the following

to be denoted as the

'gross

capita1

stock', is

Co 00

(3) K(t) = fK(t,)ds =fBsJ(t-s)ds.

0 0

6) And possibly also the definition of the functional form of the production function.

(7)

This is a technical concept, indicating the productive capacity of the capital stock at time t .

The volume of the capital worn out at time t , or the

replacement (deterioration),

can now be written as

Co

(4) D(t) = J(t) K(t) f b(s)J(t-s)ds, 0

where (if it exists)

(5) b(s) = --B1 (s) (s>0) .

The function b(s) represents the share of an initial investment (expressed in efficiency units) which disappears s years after its instalment. 7)

Let q(t) denote the investment price at time t. The current invest- ment outlay is q(t)J(t). The market value of an old capital object does not,

in general, reflect its historic cost, but rather the service flow that it is likely to produce during its remaining life time. It is this property . which is of interest to a potential purchaser (user) of capital goods.

The value of the capital vintage t—s at time t can be written as

(6) V(t,) = q t, K(t, 2

where q(t,) is the price of one capital (efficiency) unit o age s at time t, and K(t,․), as defined in eq. (2), is the number of such units.

Here we interpret the functions B(s) and b(s) deterministically. They can also be interpreted within a stochastic framework: B(s) is then the probability that a new capital unit will survive in at least s years, and b(s) is the density function of its life time.

(8)

6

We make the specific assumption that the relative prices per unit of capital objects of different ages, at each point of time,

perfectly

reflect the differences in their prospective service flows. The total flaw of capital services from one capital unit during its life time is

CO

4)(0) f B(z)dz.

0

In general,

(7) (1)(s) =

I7

1

77

-f B(z)dz'

J s

hast the:interpretation as the flow of

remaining

capital services to be

CO

produced per capital unit which has attained age s , since f B(z)dz is the service flow produced after age s by one

initial

capital unit and B(s) is the share of this unit which attains age s .8) We can then express our

assumption as follows:

(8) q(t,4)(s)) . (1)(0)q(t) - for all s>0.

Substituting (2), 7), and (8) in (6), we obtain

(9) V(t,) q(t)G(s)Vt-s),

where

Co

f B(z)dz B(s)(1)(s) s (10) G(s) - 4)(0) - 00

f B(z)dz

(s>0).

0

8) If the replacement process is interpreted stochastically (cf. footnote 7), it can be shown that c(s) represents the expected remaining life time of a capital good which has attained age s .

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The value of the capital vintage t-s at time t is thus the product of the replacement value of the original investment, q(t)J(t-s), and the share of the total service flow which is produced by one capital unit after it is years old, G(s). Aggregation over capital vintages yields the following expression for the total capital value at time t

00 CO

(11) v(t)

= f

V(t,)ds =

f

q(t)G(s)J(t-s)ds.

o

0

This value can be separated into a price and a volume

component im several ways. For our purpose, the follawing decomposition is convenient:

(12) V(t) = q(t)K.( 3

where

CO

(13) K(t) = f

G(s)J(t-s)ds.

o

We shall call K

N

(t) the

'net capital stock'.

Like the gross capital K(t), it is a volume concept constructed by aggregating the previous investment flow in volume terms, but the weighting system is basically different. The weight assigned to investment made s years ago in K

N

(t), G( ), is the

share of the total service flow produced by one unit invested

after it is years old,

whereas K(t) is based on the survival rates B(s), or, what is equivalent,on the

instantaneous service flow at age s.

From (10) and (1) it follows that G(s) has the same general properties as B(s):

(14) 05.G(s)1, Gy(s)< (if it exists) for all sA,

G(0) = 1, G(00) = 0 •

(10)

Differentiating (12) with respect to time, we get

(15) V(t) = q(t)KN (t) + q (t)K 1 (t).

We define

depreciation,

in volume terms? as the difference between the9 volume of the gross investment and the increase in the volume of the net capital stock:

CO

(16) J(t) -K(t) f g(s)J(t-s)ds,

o

where, (if it exists)

(17) g(s) = Gf(s) B(s) B(z)dz

o

the last equality following from (10). The function g(s) has the same relation to depreciation as b(s) has to deterioration; the former is in a sense the economic counterpart to the latter, technical concept,

The

(net) value of depreciation

(the true economic depreciation) is the difference between the current investment outlay and the rate if increase of the capital value:

(18) E(t. = q(t)J(t)-V(t) = q(t)D

N

(t) -q(t)K

N

(t)

CO

= q(t) f

(es)

- q(t) -G(s) 1J(t-s)ds

9) We here define depreciation as a volume concept. It can alternatively be defined "from the price side", i.e. in terms of the prices q(t,).

(Cf. e.g. Hall (1968) and Jorgenson (1974).) The two interpretations can be shown to be equivalent.

0

77-7.

(11)

Here we can interpret q(t)D(t) as the gross value of depreciation, and 4(t)K1 (t), i.e. the part of the increase in the capital value which is due to changes in the current investment price, as the value of the appreciation of the capital. Their difference is the true economic depreciation. An equivalent way of stating this is that the weight g(s) assigned to capital vintage t-s when calculating the volume of depreciation, should be replaced by the 'inflation adjusted' weight g(s) - [4(t)/g(t)]G(s) when calculating its value counterpart.

3. THE USER COST OF CAPITAL : A GENERAL FORMULA

Since one capital unit produces 0(0) units of capital services during •its total life time, and since - • in the absence of taxation - its

(effective) purchase price is q(t), q(t)/0(0) would be the price per unit of capital services at time t - or the user cost of capital in the absence of

interest costs.

To account for such costs, we replace 0(0), as defined in (7), by the corresponding service flow

discounted

at the real rate of interest p10)

CO

(19) 0 (0) . fe-PzB(z) dz,

P 0

and define the user cost as

(20) c(t q(t) _ (1(0 (I) (0) Co

P f e-Pz B(z)dz 0

10) More precisely, p is the rate of interest forgone by a producer who owns the capital_and uses its services instead of purchasing interest-

bearing financial assets.

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10

[Note that if we set p r-y, where r is the nominal interest rate and y is the rate of increase of q, and if r and y are constants, then (20) is

CO

equivalent to q(t) fe-rzc(t+z)B(z)dz.]

0

We now introduce corporate taxes into this framework. We proceed by first specifying an income tax function which comprises a wide class of tax systems as special cases, and expressing the user cost of capital in terms of the parameters of this general function. Then, in section 4, we consider some specific tax systems within this class.

Let X(t) denote the difference between the firm's output value and the total costmf all other inputs than capital at time t. The

tax function

is

(21) T(t) u[X(t) - q(t) f" s)J(—s)ds]

0

where u is the income tax rate (assumed to be constant) and p(s) is a function representing the effect of the previous investment decisions on the current income tax base: an increase in the replacement value of an investment made s years ago by one unit reduces the current tax base by 1.1(s) units. This is a general way of representing the depreciation allowances, the treatment of interest deductions and capital gains, and other factors determining the corporate taxable income. All tax systems we shall consider i section 4 can be written in this format.

The firm's net

cash—flow

at time t is

(22) 11(t) = X(t) - q(t)J(t) T(t)

CO

(1-u)x(t) - ci(t)E.gt -ufps.gt-s)ds].

o

(13)

11

Let r be the (constant) rate of (nominal) interest at which the firm can discount receipts and outlays at different points of time, and assume that Me

investment price grows at

a constant rate y . The present value of the net cash-flow can then, after some rearranging, be written as

CO

(23) • W =

1

e

-

-rtR(t )dt 0

f e7rt(1....u)[x(t 0

-

1-Au

1-u J ( t ) ] dt + W

0

,

where

co co

(24) e q ( t) (s)

J

(t-s) ds dt

and

(25) Xf e r-y)z P(z dz.

0

Since W is affected only by investment decisions made before time t =

it represents the part of W which is predetermined in relation to the firm's plans for the period [0,03).

Eq. (23) shows an interesting correspondence between the income tax (21) and a tax an the firm's. net cash-flaw: A tax on the corporate income at the rate u is equivalent to defining a corrected investment price q (t) ci(t) (1-Xu)/(1-u) and taxing the resulting net cash-flow X(t) - q

*

(t)J(t) at the rate u in each period te[0, ) 11). We shall refer to (1-Xu)/(1- ) as the fiscal factor in the following. This motivates us to modify the definition of the user cost of capital accordingly. We then get

11) This, of course, presumes the existence of a perfect financial market, by means of which the firm can transform payment streams between periods at

the interest rate r.

(14)

12

(26) c(t) q

*(t) (I) (0)

r-^r

cl(t) 1-xu 0r-.y(0) • I:tl"

or

investment price user cost of capital - present value of capital service flow

fiscal factor.

This is our general formula for the user cost of capital in the presence of corporate taxes. It is more general than the expressions usu- ally discussed in the literature since it applies to any specification of the survival function B(s) and any system of capital taxation which can be represented by the general weighting function p(s).

12)

4,. THE EFFECT OF THE TAX SYSTEM

Let us now consider, more specifically, how depreciation allowances, interest deductibility, and taxation of capital gains affect the form of the function p(s), and hence the parameter X and the user cost of capital c(t). For this purpose, we introduce the concept

accounting capital.

This is the capital concept used by the firm (and the tax authorities) for accoun- ting purposes in order to define depreciation allowances and, possibly, also for calculating interest deductions, and capital gains. We define the value of the accounting capital at time t as

12) It can be shown formally that (26) is consistent with the conditions for maximization of W with respect to J(t), subject to (3). The first order condition for this problem can be expressed as

(t) 1-Xu

1-u e -rz yt+z)B(z)dz 0

where XK( t+z) aX(t+z)/aK(t+z) is the value of the marginal product of capital services at time t+z. Since (26) implies

1-Xu-co

( t) =

fe

r zc(t4.2)13(z)dz,

1-u 0

the user cost of capital as defined above corresponds to the opportunity cost of holding capital goods in this constrained optimization problem.

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Co

(27) = f A(s) e ESq(t-s)J(t-s)ds, 0

where A(s) is the proportion of the original investment cost which is included in the accounting capital s years later, and e an inflation adjustment factor: E is the inflation rate which the firm is allowed to use for tax accounting purposes. If 6=y, the accounting capital is based on replacement cost, if E=0, it is based on historic cost, etc. The function A(s), which may be denoted as the

statutory survival function

of

the

accounting capital,

is assumed to satisfy

(28) O<A(s)< , A' <0 (if it exists) for all s>

A(0) 1, A(co) = 0,

i.e. it has the same general properties as B(s) and s); cf. (1) and (14).

The

depreciation allowances

at time t can be written as

CO Es ,

e ut-s J(t-s)ds,

where if its exists)

(30) a(s) -A' (s) •

The function a(s) represents the

statutory depreciation

rates, i.e.

the weight assigned to capital invested s years ago when calculating the volume component of the depreciation of this capital vintage. Its price component is the original purchase price inflated by e .ES

From (27)-(30) we obtain

A(t) = q(t)J(t)-D

A (t) +ENT A (t)

' 13

(29) f a

0

(16)

which shows that D

A(t) has the character as the

gross

depreciation of the accounting capital. Its net value is obtained by subtracting

the capital gains as recorded in the firm's accounts, EV A (t). Hence, in Analogy with eq. (18), which gives the true economic depreciation of the fines capital, we can define the

accounted net depreciation

as

(3 1) E

A(t) = q(t)J(t) -V

A(t) -EV A(t)

CO

f {a(s)-6A(s)leEsq(t-s)Vt-s)ds.

0

Obviously, we have EA (t) E(t) (and VA (t) = V(t)) regardless of the time path of q and J if the following two conditions are satisfied: (i) A(s) = G(s) (.*.a(s) = g(s)), i.e. the statutory survival function for the accounting capital coincides with the weighting function for the net capital, and (ii) c=y=q(t)/q(t), i.e. the rate of inflation permitted

for accounting purposes is equal to the rate of increase of the investment price.

Let m be the proportion of the (imputed) interests on the capital value which is deductible in the firm's income tax base, and n the propor-

tion of the capital gains, defined as 4(t)KN (t) ArV(t), which is included in taxable income. The tax function then becomes

(32) T(t) = tibC(t) DA(t) mrV(t) + TryV(t)].

Inserting fram (29) and (11), this implies that the function a(s) in (21) takes on the following specific form:

( 33) a(s) = a(s)e (6-Y )s + Cmr- n-y }G(s).

(17)

Define, for an arbitrary constant p, the functions

CO

(34) SY =

fe

G(s)ds,

P 0

CO

(35) Z fe-PsA(s)ds.

0

Inserting (33) in (25) and making use of (34)-(35), we find that the para- meter X in the fiscal factor can be written as

(36) X (r-e)Z + {mr-m'y }Y .

r-e r-y

The resulting formula for the user cost of capital becomes

(37) c(t) q(t)

0 (0) • 1-u r -y

-u 1-(r-e ) Z +1] -

r-e r-y

We have thus expressed the user cost of capital in terms of the in- vestment price q(t) and its rate of increase the interest rate r, the tax parameters u, e, m, and n, and the present values of the survival rates of

the gross capital 0 (0), the net capital, Y and the accounting capital,Z -

r-y r-e

Note that the first two present values are based on the market real interest rate r-y, while the third is based in the "tax permitted" real interest rate r-e. From this formula we derive three conclusions:

1. The fiscal factor will be

i

when X.1. This is thus, in general form, the condition for

neutrality

of the corporate tax system. It will be satis- fied

uniformly

(i.e. for all values of u, r, y, and G(s)) in the following cases:

(a) Depreciation allowances are based on replacement value (e.y), with the depreciation rates equal to the true rates of depre-

ciation of the net capitaltA(s) r . Y

r , full interest

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deductibility is permitted (m=1), and capital gains are fully included in taxable income (n.1).

(b) Immediate deduction of capital purchases in taxable inc(tme is permitted (Z . 1), no interest deductibility is permitted

r-e

(m=0), and capital gains are not subject to taxation (n.0).

Conclusion (a) generalizes the conclusions of Sandmo (1974, sections 4, 6 and 7), King (1975, p. 2,75), and Boadway (1980, pp. 254-255) to the situation with general survival functions of gross capital., net capital, and accounting capital. These authors consider the case with an exponentially declining survival profile (B(s) . e) and the declining balance method of deprecia--45s tion (A(s) e-mms5) only.. Conclusion (b) confirms the neutrality of the cash-flow tax.

Z. These conclusions rest essentially on the assumption that the tax permitted interest deductions, and the calculation of capital gains are based on the capital calue V(t) as defined in (12). If, however, these components are calculated on the basis of the accounting capital VA (t), as defined in (27),,the tax function (32.) changes to

ir(t) = [ X(t) D

A (t) mrV

A (t) 4 neV A(t)]

and we get

- m r -n)E}Z r-e

In this case, the condition- for neutrality (X=1) is simply m=n= 1, regardless of the values of E and Z

r-E' and hence of A(s). The interpretation of thLs is that with full interest deductibility and full inclusion of capital gains, the tax system - including the form of the accounting capital function - will not interfere with the firm's optimizing conditions, provided that

the

same accounting capital concept is used for calculating depreciation

allowances, interest deductions,

and

capital gains. This generalizes the

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conclusion in Boadway (1980, pp. 255-256), which is confined o a model with exponential depreciation allowances.

3. The distinction between the gross and the net capital concepts is indispensible for the derivation of the general user cost formula (37).

one particular case, however, their values are equal, namely the familiar

exponential

case B(s) e-6s. Then 0(s) . 1/6 and G(s) B(s) for all s, cf. (7) and (10). In this degenerate case, we have

(D) = Y"

r- r- /(r+6-y) y

If, for instance, depreciation- allowances are calculated according to the declining balance scheme A(s) = e-as(a>v), based on historic cost (e.0),

i• •

/(r+a r-c

and if m=1 and n=0, q. (37) gives the same expression for the user cost of capital as the one discussed in Boadway (1980, p. 257):

c(t) = q(t)(ri-6-y)(1 1-u)(r+d-y)(r+a)] . ur(6-y-a)

5. NUMERICAL ELLUSTRATIONS

The above results hold for any specifications of the survival function forgross capital, B(s), and of the statutory survival function for accounting capital, A(s), which satisfy (1) and (28). In this section', we consider a

selection of parametrizations of these functions to illustrate (i) the relation- ship between the curvature of B(s) and the user cost of capital, and (ii) the sensitivity of the user cost with respect to the tax parameters m, n, and e.

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For this purpose, we specify two classes of survival functions for gross capital, B(s). Both have two parameters, the first, denoted by N, representing the (maximal) life time of the capital, the second indicating the 'curvature' of the survival profile.

Class I

■■■■■■•■,

The first class has the forn

(38) B(s) = BI(s;N,T)

for 0<s<N

_

for s>N,

where N and

T

are positive13)

constants,

T

integer. Inserting this in (5), (10), and (17), we obtain

(39) b(s)

=

Ti

N N

_T

I

N

s;N, --f)

T+1 (40) G(s)

"4- s

= B (s;N,T+1),

T+1 +1

(41)

e

s) = (

1- = T B (s;N,T)

N N N

respectively.

for

0<s<N,

13) B(s), G(s), and g(s) are defined also for

T=

, but b(s) is undefined.

(21)

19

Class II

The survival function in the second class is a

(42) B(s)

s;-N,a)

for 0<s<N

for s>N,

where N and a are positive constants, a integer. This parametrization implies

(43) b(s)

as a-1

=._

7

N N s ;N,a-1 ) ] ,

(44.) G(s) =, 1

aN

a 1 1

=-

a

s,N,a+-1)

a

(4 •)

es

aN•41 a s;N

,a)

for 0<s<N .

These two parametrizations contain several specifications discussed in the literature as special cases. The case in which all capital objects retain their full productivity during N periods and are then completely scrapped, (simultaneous exit, 'one horse shay'), corresponds to class I with r=0, or class II with a-0-00. The case with a linearly decreasing survival

function B(s) is obtained. by letting 7=1

in

class I

or

a=1

in

class

II. In

this case, the survival function for net capital is simply G(s) (1 -s/N) with g(s) =(2/N)(1-s/N), which follows from eqs. (40 and (41) (or (44) and

(45)). We recognize the latter as the depreciation rates implied by the sum-of-the-years'-digits method. Furthermore, class I with T -0"c° (and N

finite) implies momentaneous scrapping of the capital once it has been installed (for practical purposes, this is equivalent to a situation with

(22)

a service life of one year). If, however, T and N both go infinity while their ratio is a finite constant cS , then class I degenerates to the

standard exponential case, B(s)=e

All members of class I in which T>2 have (strictly) convex survival functions for both gross capital and net capital (i.e. bt (s)<O,

e(s)<O).

In class II, a>2 implies a (strictly)

concave

survival function for gross capital (i.e. b'(s)>0), but a (strictly) convex survival function for net capital (i.e. gl (s)<O). There is thus no conflict between the assumption that the technical

deterioration

of the capital is

increasing

with age and the assumption that the

depreciation

(decline in capital value) is

decreasing.

Function values of B(s) and G(s) for N=10,14) with different values of a and T , are given in table 1. Corresponding values of the relative user cost of capital, c/q, with the fiscal factor set to unity (i.e. X=1), are recorded in table 2. The user cost depends strongly on the curvature of the survival profile, as characterized by

a

and T , the sensitivity is larger the lower is he technical life time.

Table 3 illustrates the sensitivity of the user cost with respect to the interest deductibility parameter m, the share of the capital gains sub- ject to taxation n, and the inflation adjustment parameter e. For simplicity, we consider only the case where the survival function of the. gross capital is of the 'simultaneous exit' type (T=0, or a --) implying a linearly declining survival function for net capital — and where the depreciation allowances are linear over T years, where T IMIY be different fram N.

The forlzh column of the bottom part of the table (T=N=20, m=n=1, and 6=y)

corresponds to the neutral tax system referred to in section 4. We observe that other constellations of the tax parameters T, m, n, and E may give large departures from neutrality, in particular when the inflation rate is high.

14 Since (38), (40), (42), and (44) are homogeneous of degree zero in s and N, it is straightforward to compute similar function values for other values of N from this table.

(23)

21

An interesting question for econometric work with invewtment equations is to which extent the standard parametrization with constrant rate cf

(technical) depreciation is an acceptable approximation for practical pur- poses. From our formulae, we can throw some light on this issue. In a stationary ;situation with constant (gross) investment, the rate of deterio-

CO

ration (i. e. D/K) will be equal to 60 1/IB(z)dz. Eqs. (38) and (42) give, 0

in particular,

T

N (class I

* 1 (class II).

aN

Let us use this as an approximation to the actual deterioration rate in situations with fluctuating investment. Assume that the actual survival profile is of the simultaneous exit type (T.0, which implies ô This suggests approximating 0 (0) and Y r

-7 by 1/(r+1/N-y) in eq. (37), r-y

since 0

ry(0) . Y

ri . 1/(r+6-y) holds exactly when the deterioration rate is

—g-

constant and equal to 6, i.e.„ in the case with exponential survival profile.

(Confer conclusion 3 in section 4 above.)

In table 4, we compare - for different values of the tax parameters m, n, and

e

- these two ways of calculating the relative user cost (c/q).

The data employed for u, r, and. y = eik are Norwegian annual data for the income tax rate (joint-stock companies), the interest rate (loans from

commercial banks to companies) and the rate of increase of the price of investment in machinery and equipment for the years 1965-1980. We find that

the series calculated from the exact formula are significantly different

(24)

from those based on the approximate formula and the latter have a tendency to exaggerate the fluctuations. In most cases, however, they move in the same direction from one year to the next.

The results in table 4 indicate that a first order approximation based on a constant rate of technical depreciation may lead to inadequate estimates of the variations in the capital cost for policyanalysis and

prediction. This conclusion will probably hold

a fortiori

if 60 is replaced by a time function equal to the observed ratio between the replacement and the gross capital stock - a common practice in empirical investment analysis.

The formulae for 0 (0) and Y , as well as their inverses, are, in general,

r-y r-y

highly non-linear expressions. In periods with fluctuating interest and infla- tion rates - as several countries have exiDerienced during the last 15 years.

the standard treatment of the replacement component in the user cost of capital may not be as innocent a simplification for empirical research as

it may first seem.

(25)

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