U.S. interest-allocation rules: Effects and policy

In 1986, the U.S. government undertook a significant reform of its income tax system. One important change for U.S. multinational corporations is related to the allocation of interest expense. This work analyzes the impact of the new U.S. interest allocation rules on the investment and financial decisions of U.S. multinationals. We test the effect of these rules on financing behavior using data from a survey of multinationals assembled by Price Waterhouse for this project. We also calculate effective tax rates for investments at home and abroad, taking the interest allocation rules into account.     

Determinants of Regional Investment Decisions in China: An Econometric Model of Tax Incentive Policy

This paper examines whether concessionary tax rates and tax incentives can attract foreign direct investment (FDI) into certain designated areas in China. Since China opened its doors to foreign investors in 1979, tax benefits have been used extensively to attract FDI into different areas. In 1991, a new tax law was introduced which superseded two previous income tax laws. This new law provides additional tax benefits which improve the investment environment for foreign investors. This study investigates the effect of China's tax rates and tax incentive policy on FDI and on the locational choices of foreign firms. Our empirical results indicate that tax rates and incentives are important determinants of regional investment decisions in China, after controlling for potential confounding variables covering infrastructure, unemployment rate, wage rate and agglomeration economics. Specifically, areas offering lower tax rates and increased tax incentives are found to attract greater amounts of FDI. The impetus of the tax effect on FDI is more apparent in the post-1991 period due to changes in the tax laws. Our results also suggest that infrastructure variables are important determinants of regional investment decisions.     

One-Way Treaty with the World: The U.S. Withholding Tax and the Netherlands Antilles

This paper chronicles the experiences of the U.S. withholding tax on interest income. In 1984, the U.S. repealed its 30 percent withholding tax on interest income paid to foreign persons or corporations. While the tax raised little revenue, it had imposed substantial implicit costs on U.S. corporate borrowers. Since, prior to repeal, domestically issued bonds were subject either to withholding or strict information requirements, many U.S. multinationals raised funds through foreign finance subsidiaries, primarily in the Netherlands Antilles, to avoid the tax. Although the withholding tax rate was effectively reduced to zero in the U.S., this paper demonstrates that interest flows were highly sensitive to their after-tax cost.     

中国公司所得税对外商直接投资的吸引力:因素剖析与能力重构

在经济全球化的背景下,许多国家降低或取消了资本限制和外汇管制,国家间公司所得税的差异成为少数几个影响国际资本流量和流向的因素之一。本文参考国外最新研究成果,将影响公司所得税对外商直接投资(Foreign Direct Investment,简称FDI)吸引力的因素分为两大类13个指标,即“税收负担水平”类和“税制完善程度”类。并认为,在内外资企业所得税合并后,针对FDI的税收负担水平可能会有所上升,但我们可以借此机会,进一步完善税制,以“税制完善程度”类的加分抵消“税收负担水平”类的减分,重构公司所得税对FDI的吸引能力。     

基于技术获取目标的我国利用FDI策略研究

当前,我国利用FDI的经济环境已经发生了巨大变化,利用FDI的主要目标是要着力发挥外资的"技术溢出效应",获取国外的先进技术。然而,由于我国企业技术吸收能力较差、外资企业不愿技术扩散,以及我国不利的外部环境等多方面原因,导致我国获取FDI技术的效果一直不明显。因此,必须从政府和国内企业两个层面着手,通过制定有利于技术获取的引资政策、营造高度竞争的市场环境、提高国内企业对技术的学习和吸收能力等措施,以促进技术获取目标的实现。     

The Destination of Outward FDI and the Performance of South Korean Multinationals

This paper examines how the destination of outward foreign direct investment (FDI) affects South Korean multinational parent firms. We categorize host countries into those that are developed and those that are less developed. We find that destination matters for employment and capital intensity. FDI into less developed countries is negatively associated with a firm's employment and positively associated with its capital intensity. However, FDI into developed countries does not seem to matter: the parent firm's activities do not change significantly after FDI has been made. These results may indicate that Korean FDI into less developed countries is a relocation of production lines to overseas affiliates and FDI into developed countries is done to extend markets.     

我国外商直接投资税收敏感性分析

采用现状分析、理论论证和实证分析等经济分析方法,对税收政策对外商投资的影响作用进行分析,可得出以下结论:税收优惠对吸引外商直接投资有促进作用,但其影响作用并不显著。我国应正确对待税收优惠的作用地位,并全面考虑影响优惠政策的因素,采用更为有效的税收优惠工具,有的放矢地运用税收优惠政策。     

沉淀投资、税收政策竞争与跨国公司发展

如果没有公平的竞争环境,跨国公司的发展会受到限制,可以说建立一个公平竞争的国际环境是跨国公司得以发展的最根本的前提。事实上,公平竞争环境不仅包括产品市场竞争、生产要素市场竞争和金融市场竞争,而且还包括税收政策竞争等经济政策竞争。这些竞争环境都是跨国公司发展的必要国际条件。     

双边税收协定与CFC税制关系探讨——兼谈《中华人民共和国企业所得税法》第58条

长期以来,双边税收协定与CFC税制关系问题存在争议。一般认为,受控外国公司税制作为一种重要的反避税措施,它与双边税收协定是兼容的。但是,从一些欧盟国家的实践来看,观点并非一致。由于《中华人民共和国企业所得税法》中规定了该项税制,因此,解决两者的兼容性也是将要面临的问题。在我国《宪法》没有对条约在国内法中地位进行规定之前,《中华人民共和国企业所得税法》第58条应予以完善。     

中国吸引外资、对外投资和对外贸易:历史与未来

中国已经成为全球外国直接投资的主要接受者,同时也是世界上第二大对外直接投资国。中国希望通过扩大对外直接投资学习先进技术和管理经验,并帮助国内企业分散风险。在改革开放推动下,中国逐步成为一个世界贸易强国,其主要贸易伙伴遍布欧美、东南亚及日本、韩国等,制造业产品在中国对外贸易中占比较大。     

关于转让定价税务管理的国际协调问题

为避免各国在转让定价税务管理中引发新的矛盾,必须加强国家间的协调与合作。因此,需要对转让定价税务管理中涉及的国际协调问题进行分析,包括:各国转让定价税务管理依据的指导原则和具体方法;转让定价的初次调整和相应调整的配合;转让定价税务管理国际争议的协调机制等。     

Why Capital Income Taxes Survive in Open Economies: The Role of Multinational Firms

This paper discusses the role of multinational firms and double taxation treaties for corporate income taxation in open economies. We show that it is optimal for a small open economy to levy positive corporate income taxes if multinational firms are taxed according to the full taxation after deduction system or the foreign tax credit system. Positive corporate taxes also occur in the asymmetric case where some countries apply the exemption system and others apply the tax credit system. If all countries apply the exemption system, the optimal corporate income tax is zero. We also show that, under tax competition, corporate income taxes are not necessarily too low from the perspective of the economy as a whole. While the undertaxation result is confirmed for the case of the exemption system, tax rates may also be inefficiently high if the deduction or the credit systems are applied.     

Political Risk as a Determinant of Southern European FDI in Neighboring Developing Countries

This study analyzes foreign direct investment flows from southern European countries to one of two nearby developing regions: north African countries and new European Union member states in central and eastern Europe. As expected, good economic perspectives, human capital, and development of infrastructures attract greater investment flows. However, greater levels of political risk, measured through scales of political discretion, corruption, and economic freedom, do also attract higher inflows. Despite the fact that one might expect global flows to fall as a consequence of political risk, those from the countries in the sample increase, because they come from firms that are searching for a market niche where they can take advantage of their political capabilities.     

The impact of tax on foreign direct investment: Empirical evidence and the implications for tax integration schemes

We estimate the impact of taxation on foreign direct investment (FDI) flows, using data on flows between seven countries for 1984 through 1989, and a sophisticated measure of the cost of capital. We find that the choice between domestic investment and total outward FDI is not significantly affected by taxation but that taxation does affect the location of outward FDI. These results are used to examine the impact of tax integration systems. Giving a tax credit to foreign shareholders may induce a large increase in inward FDI from exemption countries but not from partial-credit countries. For the United States, the total effect would be small.     

Not Every Kind of Outward FDI Increases Parent Firm Performance: The Case of New EU Member States

Using a large firm-level dataset we investigate what kind of firms from new EU member states from Central and Eastern Europe (CEECs) tend to invest abroad (testing of self-selection hypothesis), and what is the impact of outward FDI on their productivity (testing of learning-by-investing hypothesis). We find that the best firms tend to self-select into outward FDI. There is also a positive effect of outward FDI on productivity growth of investing firms from CEECs, the strongest being in the case of Estonia, Romania, Czech Republic, and Slovakia. The positive impact of becoming a first-time foreign investor is relatively long lasting, but comes into effect only in investments in Western European or other CEECs and in the case of manufacturing subsidiaries.     

The capital structure of multinational corporations: Canadian versus U.S. evidence

Contrary to the U.S. evidence, we show that Canadian multinational corporations (MNCs) display higher leverage than domestic firms (DCs). This higher leverage is due to lower agency costs of debt associated with MNCs' U.S. operations. We also find that the Canadian firms with international bond market access have higher leverage than firms without such access. Comparison with a U.S. matched sample shows that the sensitivity of leverage to firm-specific factors differs between the two countries, especially for the MNCs samples. Our evidence indicates that capital structures of MNCs are a complex interaction of both home and host country factors and differences in leverage determinants across countries.     

The incentive to locate a multinational firm: The effect of tax reforms in the United Kingdom

The advent of the single European market has focused attention on the structure of international tax incentives for the location of multinational business. Multinationals that channel foreign income through the United Kingdom have been likely to suffer double taxation in the form of surplus advance corporation tax when they subsequently distribute the income to a foreign parent. This paper shows that the 1993 U.K. tax reforms create a significant reduction in the tax cost of locating in the United Kingdom, relative to traditionally favorable tax regimes such as the Netherlands.     

税收优惠的国际竞争与影响

税收优惠竞争具有促进自由竞争、保障发展中国家的利益、保障外国投资者利益、对征税权力的约束的正面影响,也具有破坏生产效率、损害税收公平与社会福利、侵蚀其它地区的税基、破坏所得税的累进效果等负面影响。我国在新时期的税收优惠调整中,应该根据税收优惠竞争的正、负面影响综合考虑吸引投资与全民福利最大化双重因素。     

证券投资基金纳税主体资格的法律确证

当前,对证券投资基金课税存在问题的症结在于其法律性质和地位,从证券投资基金财产的独立性、基金外部管理者的运行架构以及运行效果可以看出,证券投资基金具有组织体的特性,并具有独立的税法主体资格。在明确这些问题后,可以分别从证券投资基金、基金管理人和托管人、投资者三个不同的纳税主体来重新构建我国的证券投资基金税制。