The economic consequences of corporate tax rates reductions in the EU: Evidence using a computable general equilibrium model

In a globalised world, governments are eager to attract foreign investors by lowering corporate tax rates. Recent trends point towards a revival of a race to the bottom in corporate income tax (CIT) rates in developed economies. EU countries have been active in this respect. A generalised fall in CIT rate could prove detrimental to tax revenues and trigger increase in other taxes to meet fiscal policy objectives. However, it could also spur investment and growth and prove to be a good fiscal policy strategy if, as a result, the corporate tax base increases. The final economic and fiscal impact of a reduction in CIT rates is therefore unclear. Using a CGE model, we find that uncoordinated tax reforms significantly impact national economies and third‐country effects can be significant when large countries implement CIT rate cuts. Small countries are better off unilaterally reducing their CIT rate at the expense of other EU countries. We find that negative spillovers are mitigated when the country reducing its CIT rate restores its budget balance by cutting either public expenditures or social transfers. A larger degree of non‐EU capital mobility also tends to reduce the negative spillover effects of unilateral CIT rate reductions.     

K?rperschaftsteuers?tze, Verlustverrechnung und Steuerwettbewerb in der EU

This article describes the developments in corporate tax rates and loss-offset provisions in the EU countries and addresses the question of whether the new member states of the EU are applying lower tax rates and therefore boosting their loss-offset restrictions. Such a harmful tax competition has been feared with regard to the case law of the European Court of Justice that considers the cross-border loss offset. This study shows the opposite is true. In recent years, especially the new EU member states have extended the loss carry-forward period.     

Who benefits from partial tax coordination?

In this paper, we investigate whether partial tax coordination is beneficial to countries within and outside a tax union, in which countries are supposed to compete in taxes and infrastructure. Our results demonstrate that a subgroup of countries agreeing on a common tax rate can harm both member and nonmember states. This is in contrast to the classical findings that partial tax harmonisation is Pareto improving. When a minimum tax rate is imposed within a tax union, we demonstrate that it does not necessarily improve the welfare of the member countries. Moreover, both the high‐tax and low‐tax countries can be worse off. This conclusion is at odds with the classical result that a high‐tax country benefits from the imposition of a lower tax bound.     

欧盟各国税收制度竞争与协调现状分析

伴随着欧洲经济一体化的不断扩大,欧盟各国普遍采用税收竞争的手段来吸引外来投资,改善本国企业竞争力,对于这种税收竞争所带来的后果,各国评价不一.文章试图通过对欧盟各国税收既有竞争又希望协调的现状进行分析,来探讨如何在欧盟内部消除有害税收竞争,实现税收协调的目标.     

Imperfect tax competition for profits, asymmetric equilibrium and beneficial tax havens

We present a model of tax competition for real investment and profits and show that the presence of tax havens in some cases increases the tax revenue of countries. In the first part of the paper, we argue that tax competition for profits is likely to be imperfect in the sense that the jurisdiction with the lowest tax rate does not necessarily attract all shifted profits. Under this assumption, tax competition between a large number of identical countries may lead to either a symmetric equilibrium with no profit shifting or an asymmetric equilibrium where firms shift profits from high-tax to low-tax countries. In the second part of the paper, we introduce tax havens. Starting from a symmetric equilibrium, tax havens unambiguously reduce the tax revenue of countries due to a ‘leakage effect’ — tax havens attract tax base from countries — and a ’competition effect’ — the optimal response to the increased tax sensitivity of tax bases involves a reduction of tax rates. Starting from an asymmetric equilibrium, however, tax havens also raise the tax revenue of countries through a ’crowding effect’ — tax havens make it less attractive to compete for profits and thus induce low-tax countries to become high-tax countries. We demonstrate that the latter effect may dominate the former effects so that countries, on balance, benefit from the presence of tax havens.     

On the measurement of investment types: Heterogeneity in corporate tax elasticities

This paper contributes to debates about the appropriate characterisation of heterogeneous investment types and to what extent different investment motives affect the responsiveness to corporate taxation. In particular, we employ and refine a methodology to better evaluate the tax elasticity of investment types. Using a combination of both firm‐specific information and sector‐specific information from input–output tables, we discuss how to classify investment as non‐related, horizontal, vertical and complex types. First, we point out to what extent the resulting classification depends on assumptions made by the researcher. Second, we employ an ample set of classifications and find that non‐related investment reacts stronger to corporate taxation, whereas horizontal investment is less responsive, though, significant negative tax semi‐elasticities turn out for the subset of manufacturing industries. To address inherent characteristics of vertical and complex investment, we extend the methodology and find that, by and large, stronger business motives reduce the tax responsiveness of investment to a larger extent. Given the current debates about substantial corporate tax reforms, it is all the more important to recognise that corporate tax effects can vary fundamentally between countries, driven by country‐specific differences in their composition of industries and investment types.     

The tax reform agenda

High tax rates that distort incentives and create large deadweight losses have been reduced, but there is still much more to be done to improve the tax system. It is useful to distinguish between tax rules that represent tax expenditures relative to a pure income tax from rules that represent tax expenditures relative to a consumption tax. I think it is important to focus on tax expenditures relative to a consumption tax base. It is possible that if there were no estate tax, the present value of the taxes paid by future heirs would exceed the revenue lost by abolishing the estate tax. On the corporate side, a shift to a territorial system of taxation would have very substantial favorable effects, while pass-through entities have a very weak case for a significantly lower tax rate. The net effect of such tax changes would be an increase in the budget deficit, though that increase is likely to be only temporary due to legislative rules. I am optimistic that there will be tax reforms enacted in the next twelve months holding great promise for improving our tax system and our economy.     

The determinants of tax haven FDI

This paper examines the determinants of a multinational enterprise's (MNEs) decision to set up tax haven subsidiaries. We adapt the firm-specific advantage–country-specific advantage (FSA–CSA) framework and construct a number of empirically testable hypotheses. The analysis is based on a database covering 14,209 MNEs in twelve OECD countries. We find that the variety of capitalism of a MNEs home location and the level of technological intensity has a strong impact on this decision. We also find that the home country corporate tax rate has a minimal impact. This suggests that corporate tax liberalisation is unlikely to deter MNEs from undertaking this activity.     

欢盟外资并购国家安全审查制度对中国的启示

21世纪以来,欧盟主要国家纷纷修改外资并购立法,加大对外资并购国冢安全的审查,审查标准趋亍严格．审查范围愈发扩大。这种外资审查立法权扩张的冲动受到来自《欧共体条约》所确立的资本自由化原则的制约。在国际投资政策趋紧的背景下,中国公司近年来在欧美国家的外资并购不断受阻。深入理解欧盟外资并购立法的规定是当前中国企业制定国际化战略的基本要求。     

Effects of Corporate Tax Reforms on SMEs’ Investment Decisions under the Particular Consideration of Inflation

Corporate tax reforms carried out in EU countries since 1980 entail lower statutory tax rates and reductions in generous tax depreciation provisions. Several countries including the UK have reduced tax rates for small and medium sized enterprises (SMEs). This study compares incentive effects of such reforms on the SMEs’ investment decisions adopting a simple present value model. Ceteris paribus, tax rates and depreciation rules vary in the model simulation, while the application of historical cost accounting method in inflationary phases leads to fictitious increases in nominal net present value. Apart from the construction of international ranking, country-specific patterns of reform effects are also illustrated. This paper was presented at the 61st Congress of the International Institute of Public Finance (IIPF) held in Jeju Island, Korea in 2005. The authors are grateful to discussants and participants at the conference. Special thanks to two anonymous referees for helpful comments. Responsibility for errors remains the authors’.     

Trade openness,tax reform and tax revenue in developing countries

This article investigates empirically whether the effect of tax reform (involving the progressive replacement of trade tax revenue with domestic tax revenue) in developing countries' tax revenue performance (measured by tax revenue‐to‐GDP ratio) depends on the degree of trade openness of these countries. The analysis has used an unbalanced panel data set of 95 developing countries over the period 1981–2015 and the two‐system GMM approach. Results suggest that tax reform is positively and significantly associated with tax revenue performance in developing countries, with the magnitude of this positive effect increasing as countries experience a higher development level. Additionally, and more importantly, countries that further open up their economies to international trade enjoy a higher positive effect of tax reform on tax revenue than countries that experience a lower degree of trade openness. Therefore, these findings should help dissipate the concerns of policymakers in developing countries that greater openness to international trade would further erode their tax revenue, including by lowering their international trade tax revenue. In fact, the implementation of an appropriate tax reform in the context of greater trade openness would generate higher tax revenue, while concurrently allowing countries to reap the well‐known benefits of international trade.     

Valuation and firm investment and financing policies with personal tax biases

In this paper we examine firm financial policies in the presence of personal tax biases (e.g., favoring capital gains relative to interest and dividends). A form of the value additivity principle (VAP) for the tax bias case is established and applied to the firm's merger, investment, financial structure, and dividend decisions. As with the neutral tax VAP, the revised VAP requires transaction costless capital markets but does not require capital market completeness or competitiveness. Share value maximization is found not to be the proper goal for a firm that seeks to maximize the shareholders' current expected utility; however, it is found that share value maximization is generally a good approximate objective. Firm investment policy with financial structure irrelevance (owing to offsetting personal and corporate taxes) is examined assuming that the revised VAP holds.     

Energy policy: European,national, regional?

When it comes to energy policy, EU countries go their own way with little regard for other member states. What strategies exist in the EU Commission to coordinate and integrate energy markets? Are these strategies consistent with national plans currently in action? Is it too late to establish a unifi ed energy policy? What can be achieved in a unifi ed energy policy given the considerable differences in resource endowment and political preferences in energy strategies? Can the effectiveness of EU energy policy objectives be enhanced through policy coordination at the regional scale? This Forum seeks to provide answers to these questions.     

Wie sollte das Steuersystem in Deutschland reformiert werden?

Some authors focus on the fact that Germany shows one of the highest tax burdens among the OECD countries. Based on their analysis, they suggest approaches to reduce the tax burden in particular for lower and medium incomes. These tax reliefs are possible, and would not compromise new public investment. But decreases in personal income tax rates mainly relieve higher income earners and are accompanied by high tax losses if the top tax rates are not increased. Alternatives are relief for social contributions or VAT. Other researchers do not look at the tax burden this way: as the income tax burden in Germany is not high from a historical perspective or by international standards, there is no case for massive tax cuts, as this would jeopardise the government’s ability to act and fail to correct past shifts of the tax burden at the expense of households with low incomes. Any tax cuts should be targeted at the bottom half of the income distribution without creating any revenue shortfalls. Instead, the government would be well advised to increase its efforts to overcome the public investment backlog and ensure a well functioning civil service. Furthermore, sustainability oriented tax reforms should focus on a shift of the tax burden from taxes on labour towards environmental and wealth based taxes.     

Steuerflucht und Steueroasen

The current debate on tax planning has to distinguish between tax evasion and aggressive tax planning. While tax evasion is illegal and requires the enhanced exchange of information, measures against aggressive tax planning seem to be very complex and complicated. Tax havens’ benefits from tax haven activities are inversely related to the intensity of competition among tax havens. Once the set of tax havens narrows, each havens’ share of the business increases and its margins go up. This competition aspect makes initial successes easy but final success very difficult. Nevertheless, some authors argue that action against tax flight is inevitable. As tax flight is a multilateral phenomenon, coordinated initiatives by country groups appear particularly promising. Here the EU should be in the vanguard. Only automatic information exchange generates the transparency and leeway needed to eliminate income tax evasion and to permit countries to devise tax codes at their own discretion. Despite the European trend towards lower corporate taxes, an empirical analysis shows that German multinationals have increased their tax haven activities. Recent research suggests that this development might be explained by the increased usage of anti-tax avoidance measures by high-tax countries. The substitutive nature of different tax-avoidance schemes indicates that only a coordinated closing of loopholes for profit shifting would reduce the demand for tax-haven operations significantly.     

Corporate tax systems, multinational enterprises, and economic integration

Multinational firms are known to shift profits and countries are known to compete over shifty profits. Two major principles for corporate taxation are Separate Accounting (SA) and Formula Apportionment (FA). These two principles have very different qualities when it comes to preventing profit shifting and preserving national tax autonomy. Most OECD countries use SA. In this paper we show that a reduction in trade barriers lowers equilibrium corporate taxes under SA, but leads to higher taxes under FA. From a welfare point of view, the choice of tax principle is shown to depend on the degree of economic integration.     

Why do countries combine the exemption system for the taxation of foreign profits with domestic double taxation relief?

Many European countries exempt foreign profits from domestic corporate taxation. At the shareholder level, however, all corporate profits are taxed, and double taxation relief is granted only for domestic corporate taxes. This paper attempts to rationalize this tax policy. In the presence of double taxation agreements which exempt foreign profits from domestic corporate taxation, countries may use shareholder taxes to tax these profits. The disadvantage of shareholder taxes is that they create incentives to sell domestic firms to foreigners. But double taxation relief for domestic profits may preserve domestic ownership. Our results imply that national dividend tax policies may be a factor contributing to the empirically observed home bias in investment.     

Labour demand in the EU and returns to scale: A production function approach

The paper tests the hypothesis that small member states of the European Union (EU) experience economies of scale constraints. This study adopts a production function approach, utilising data from the 27 differently sized EU member countries. The results confirm the hypothesis and indicate that larger EU member countries incur lower costs per unit of output produced when compared to the smaller ones. This finding has important implications for small EU member states, including that smaller countries have to overcome their economies of scale constraint in order to attain and maintain international competitiveness. This disadvantage is particularly relevant for small states, because these states tend to be highly dependent on international trade, in which case international competitiveness is a major issue.     

Investitionsschutzabkommen: mehr Rechtssicherheit oder verzicht auf Souveränität?

Bilateral investment treaties (BITs) and investor-state dispute settlements (ISDS) have become highly controversial. The authors review the evidence and discuss the pros and cons of BITs and other investment agreements. Many observers are concerned that Transatlantic Trade and Investment Partnership (TTIP) regulations on investment protection could be abused by international corporations to obtain unjustifi ed compensation from EU member states. These concerns are to some extent legitimate and should be considered more seriously in the EU negotiation strategy. International investment agreements (IIA) are necessary when host countries of FDI do not have reliable and independent judicial systems. To avoid abuse and to account for the increasing role of global production chains, agreements require more precise defi nitions, and ISDS needs to be more transparent and independent. With the EU developing its own new approach independently (and differently) from the one taken in the past by its member states, the current negotiations of “mega-regionals”, as well as the fi rst standalone EU IIA with China, offer the unique possibility to answer current critique around international investment law. Is there, in the current documents, an IIA2.0 that strengthens the right to regulate and holds up high protection standards for investors? The exclusion of ISDS from TTIP negotiations risks missing a unique chance to improve the current less than perfect international investment regime.     

Does Corporate Taxation Deter Multinationals? Evidence from a Historic Event in Ireland

We use a unique exogenous corporate tax policy change in the Republic of Ireland to investigate how corporate taxation affects foreign direct investment at the extensive and intensive margin. To this end, we construct exhaustive sectoral and plant level panel data and use difference‐in‐differences strategies. Our results do not provide strong evidence that the increase in corporate tax rates for exporters did affect the entry or exit of plants from the US or UK in Ireland. Entry rates of German firms seem to be negatively affected, however. At the intensive margin, there is evidence that foreign plants in Ireland reduce the size of their operations in response to the tax change.