This paper analyses how the government should tax internationally mobi
le firms. The analysis finds that if tax authorities are unable to obs
erve firms' true mobility, and domestic and foreign profitability are
uncorrelated, then: (1) information rents are acquired by immobile (in
efficient) firms, and (2) the optimal policy will stimulate investment
in the immobile sector compared to the complete information case. Ano
ther result of the paper is that the optimal allocation is implementab
le within the framework of a corporate income tax system, where mobile
firms self-select more unfavourable capital allowances than immobile
firms. (C) 1998 Elsevier Science B.V.