Conflicting Transfer Pricing Incentives and the Role of Coordination

Our study evaluates the role of coordination, at both the government and the firm level, on the transfer prices set by U.S. multinational corporations (MNCs) when income taxes and duties cannot be jointly minimized with a single transfer price. We find that either the presence of a coordinated income tax and customs enforcement regime or coordination between the income tax and customs functions alters transfer prices for these firms. Our analyses have implications for both firms and taxing authorities. Specifically, our findings suggest that MNCs might decrease their aggregate tax burdens by increasing coordination within the firm or that governments might increase their aggregate revenues by improving coordinating enforcement across taxing authorities. Our study is novel in that we document, in a specific setting, how coordination influences MNCs’ tax reporting behavior.     

Tax‐Avoidance Activities of U.S. Multinational Corporations*

This paper investigates whether economies of scale exist for tax planning. In particular, do larger, more profitable, multinational corporations avoid more taxes than other firms, resulting in lower effective tax rates? While the empirical results indicate that, ceteris paribus, larger corporations have higher effective tax rates, firms with greater pre‐tax income have lower effective tax rates. The negative relation between effective tax rates (ETRs) and pretax income is consistent with firms with greater pre‐tax income having more incentives and resources to engage in tax planning. Consistent with multinational corporations being able to avoid income taxes that domestic‐only companies cannot, I find that multinational corporations in general, and multinational corporations with more extensive foreign operations, have lower worldwide ETRs than other firms. Finally, in a sample of multinational corporations only, I find that higher levels of U.S. pre‐tax income are associated with lower U.S. and foreign ETRs, while higher levels of foreign pre‐tax income are associated with higher U.S. and foreign ETRs. Thus, large amounts of foreign income are associated with higher corporate tax burdens. Overall, I find substantial evidence of economies of scale to tax planning.     

Innovation and Corporate Tax Planning: The Distinct Effects of Patents and R&D*

Using a large US sample, we find a significant and positive relation between patents and corporate tax planning, and the effect is incremental to the effect of R&D on tax planning. We employ a quasi‐natural experiment based on staggered industry‐level innovation shocks to identify the positive causal effect of patents on corporate tax planning. We also find that patents are not associated with tax planning for domestic firms, but their association with tax planning is concentrated in multinational firms, which have the ability to shift domestic income to low‐tax countries. Moreover, we find that the identified effect mainly exists in the post–check‐the‐box (CTB) rule period when shifting income among affiliates becomes more flexible and convenient. Finally, we use two income‐shifting models and find that patents, rather than R&D, facilitate tax planning through an income‐shifting channel. Overall, our results suggest that R&D and patents facilitate firms' tax planning in distinct ways: R&D facilitates tax planning as intended through tax credits and deductions, whereas patents are used by taxpayers to avoid taxes aggressively through income shifting.     

Tax and leverage: Evidence from China

This study exploits two institutional features of China to test the causal link between tax and capital structure. First, the central government exclusively determines the corporate tax rate in China, which results in changes in corporate income tax rates across different Chinese public firms over the period of 2000–2011. Such mandatory tax shifts provide a quasi-natural experimental setting for our difference-in-differences analysis investigating the impact of tax on leverage. We find evidence supporting the dynamic trade-off theory, namely that firms are unresponsive to tax cuts but increase long-term leverage when taxes rise (particularly those in low statutory tax regimes). Second, governmental intervention in capital allocation is common in China such that political connections are usually regarded as an asset for firms in accessing bank loans. Using anti-corruption events as shocks to the value of political connections over the sample period, our research is the first study to show that political connections become a liability that enables banks to recall loans from affected firms during the anti-corruption campaign periods. This change overturns the typical tax-leverage relationship observed, as we find anti-corruption affected firms reduce long-term leverage when taxes are cut and they become insensitive to tax increases. Our results reveal the importance of political ties in explaining how firms adjust their capital structure to tax changes, which is extremely relevant to policy makers and regulators when monitoring bank loan markets.     

Economic policy uncertainty,tax quotas and corporate tax burden: Evidence from China

This paper studies how economic policy uncertainty affects corporate tax burden. We show that economic policy uncertainty is positively related to corporate tax burden, and the effect is stronger when the tax quotas are higher. Furthermore, we find that economic policy uncertainty strengthens tax collection by increasing government fiscal pressure, thereby increasing corporate tax burden. Besides, the effects of economic policy uncertainty on corporate tax burden are primarily significant in state-owned enterprises (SOEs), non-high-tech firms, firms from the eastern areas and service industry firms. The evidence illustrates that keeping the transparency and stability of economic policies helps to cut tax burden effectively.     

Bribery in Indonesia: some evidence from micro-level data

This paper outlines and tests a model in which firms seek to reduce the cost of taxes and regulatory compliance by offering bribes to government officials. It finds that firms' profitability (scaled by production costs) largely determines both the amounts paid and the time spent negotiating bribes with officials. Competition between arms of the bureaucracy for bribe income seems to be a result of decentralisation, but the analysis suggests that this competition would lead to a spreading of bribes among a larger number of officials rather than to a significant increase in their total amount. Local governments may be able to raise more revenue by reducing the number of taxes and regulations and using part of the increased revenue to raise the salaries of officials, while devoting more effort to restraining corrupt behaviour. But progress may be blocked by central government tax officials increasing their demands for bribes.     

Preferential corporate income tax treatment: Valuation in the market portfolio

In the setting of the market portfolio, the impacts of preferential corporate income tax treatments through the valuational reduction for risk are opposite to and offset the impacts through the expected proceeds. This suggests that focusing on the absolute valuation of tax-favored firms results in the undermeasurement of implicit taxes on returns on investments in tax-favored firms and the relative valuation with reference to fully taxed (i.e., tax-disfavored) benchmark firms be used. In addition, corporate income taxes imposed on entities and capital income taxes imposed on investors have opposite valuational effects through the endogenously derived market-aggregate aversion to risk.     

Transfer Pricing: Strategies,Practices, and Tax Minimization

Using a survey of tax executives from multinational corporations, we document that some firms set their transfer pricing strategy to minimize tax payments, but more firms focus on tax compliance. We estimate that a firm focusing on minimizing taxes has a GAAP effective tax rate that is 6.6 percentage points lower and generates about $43 million more in tax savings, on average, than a firm focusing on tax compliance. Available COMPUSTAT data on sample firms confirm our survey‐based inferences. We also find that transfer pricing‐related tax savings are greater when higher foreign income, tax haven use, and R&D activities are combined with a tax minimization strategy. Finally, compliance‐focused firms report lower FIN 48 tax reserves than tax‐minimizing firms, consistent with the former group using less uncertain transfer pricing arrangements. Collectively, our study provides direct evidence that multinational firms have differing internal priorities for transfer pricing, and that these differences are strongly related to the taxes reported by these firms.     

Corporate Taxes and Financing Methods for Taxable Acquisitions*

We examine the influence of corporate taxes on U.S. firms' financing methods for taxable acquisitions of 100 percent of a target corporation's stock. We conduct tests of acquirer firms' use of debt or internal funds as the funding source for these acquisitions over the period 1987‐97. Our results provide the first empirical evidence that U.S. firms' use of debt to fund acquisitions significantly declines as foreign tax credit limitations reduce the marginal tax benefits received from borrowing. This finding is consistent with earlier speculation that U.S. foreign tax credit provisions could materially affect the capital costs of U.S. companies in debt‐financed acquisitions. We also find that these firms are generally high‐tax‐rate corporations whose financing choices are not significantly influenced by whether they acquire target‐firm tax loss carryovers. Our findings contribute to the accounting literature on the influence of taxes on the structure and financing of corporate acquisitions.     

Does Competition Lead Firms to Bribery? A Firm-Level Study in Southeast Asia

Economists have paid close attention to economic development in Southeast Asia, where corruption and bribery are believed to be ubiquitous. In this article, we study the reasons why firms bribe. Specifically, we study the effects of the competition encountered by Southeast Asian firms on their bribing behavior. This article focuses on two types of bribing behavior: (1) informal payments given to the government so that it will ignore rule violations and (2) informal payments to the government to secure a contract. Using firm-level and country-level data from Cambodia, Indonesia, Laos, Myanmar, the Philippines, and Vietnam between 2009 and 2014, we find that the market competition will increase bribing behavior, while political competition within the country will reduce the likelihood of bribing.     

Taxes and the Financial Structure of German Inward FDI

The paper analyses the financial structure of German inward FDI. Intra-company loans granted by the parent should be all the more strongly preferred over equity the lower the tax rate of the parent and the higher the tax rate of the German affiliate. We find that the corporate tax rate of the foreign parent has no significant impact on the financial structure of a German subsidiary. However, among subsidiaries that are directly held by a foreign investor those firms that on average are profitable react more strongly to changes in the German corporate tax rate than this is the case for less profitable firms. This gives support to the frequent concern that high German taxes are partly responsible for the high levels of intra-company loans. Taxation, however, does not fully explain the high levels of intra-company borrowing. Roughly 60 per cent of the cross-border intra-company loans turn out to be held by firms that are running losses. JEL no. F23, H25     

Corporate Political Connections and Tax Aggressiveness

This study investigates the relation between corporate political connections and tax aggressiveness. We study a broad array of corporate political activities, including the employment of connected directors, campaign contributions, and lobbying. Using a large hand‐collected data set of U.S. firms' political connections, we find that politically connected firms are more tax aggressive than nonconnected firms, after controlling for other determinants of tax aggressiveness, industry and year fixed effects, and the endogenous choice of being politically connected. Our findings are robust to various measures of political connections and tax aggressiveness. These results are consistent with the conjecture that politically connected firms are more tax aggressive because of their lower expected cost of tax enforcement, better information regarding tax law and enforcement changes, lower capital market pressure for transparency, and greater risk‐taking tendencies induced by political connections.     

How Aggressive Tax Planning Facilitates the Diversion of Corporate Resources: Evidence from Path Analysis

In measuring tunneling with intercorporate loans disclosed by Chinese listed companies, we analyze the underlying channels through which aggressive tax planning facilitates the diversion of corporate resources by firm insiders. Using path analysis, we document that the path from tax aggressiveness to related loans is mediated by both the additional cash flows from tax savings and the increased financial opacity from tax planning, and that additional cash flows plays a much more important role than opacity in helping controlling shareholders to divert corporate resources under the guise of tax aggressiveness. Beyond the two mediated paths, we also detect a residual, direct path from tax aggressiveness to related loans. After an exogenous shock from the government crackdown on diversionary related loans, we find the direct path is fully mediated by the two indirect paths, suggesting that tunneling via related loans only occurs at firms where insiders can mask tunneling under the cover of opacity or can justify related loans on grounds of abnormal cash flows from tax savings. Our evidence supports the notion that greater outside scrutiny increases the hurdle for, but does not entirely eradicate, diversion facilitated by tax aggressiveness. Collectively, our research lends some support to recent theory on the importance of taxes to corporate governance by demonstrating how the agency costs of tax planning allow certain shareholders to benefit from firm activities at the expense of others.     

The Effects of the Tax Cuts and Jobs Act of 2017 on Defined Benefit Pension Contributions*

This study examines the effect of the Tax Cuts and Jobs Act of 2017 (TCJA) on corporate defined benefit pension contributions. The TCJA decreases the corporate tax rate from 35 percent in 2017 to 21 percent in 2018 and thereafter. This change incentivizes firms to increase 2017 pension contributions to take advantage of tax deductions at a higher rate. Consistent with this incentive, we find firms increase defined benefit pension contributions by an average of 25 to 31 percent in 2017 compared with earlier years. We also find that taxpaying firms are the primary contributors. Further, taxpaying firms with high levels of pension-related deferred tax assets contribute over three times as much as taxpaying firms with low levels of pension-related deferred tax assets. We also find firms that increase pension contributions in 2017 reduce 2018 contributions, consistent with intertemporal income shifting rather than a permanent change in pension funding strategy.     

Tolerance of tax evasion

We present a formal model in which individuals want the government to tolerate tax evasion because, in a context of limited state capacity, evasion provides insurance. Also, preferred tolerance of tax evasion increases with income, because government programs are redistributive, and decreases with perceived state capacity, because taxation is less distortionary in more capable states. We test the model using a question in the World Values Survey (WVS) about how justifiable cheating on taxes is. We find that tax evasion justifiability views present an inverted-U shape in perceived risk and increase with individuals’ income.

     

Tax incentive and corporate financial performance: Evidence from income tax revenue sharing reform in China

How to stimulate corporate performance is a crucial issue of general concern in all countries. This paper examines how China’s Income Tax Revenue Sharing Reform in 2002 affects corporate financial performance. Unlike general tax policies that directly adjust the nominal tax rate or depreciation allowance, this reform indirectly affects the effective Enterprise Income Tax (EIT) rate by switching tax administration, thereby affecting corporate financial performance. We use a firm-level data-set from Annual Survey of Industrial Firms (ASIF), and test the impact by using a quasi-natural experimental design through regression discontinuity design (RDD). We find that after the reform, the effective EIT rate (ETR) of enterprises collected EIT by State Administration of Taxation (SAT) was 10% lower than that of enterprises collected EIT by the Local Administration of Taxation (LAT). If the ETR reduces by 1%, corporate financial performance, more specific, Return on Asset (ROA), increases by 1.7%. There are two available channels: increasing fixed asset investment (FAI), and alleviating external financial constraints. Additionally, the impact can be weakened for locally SOEs, large firms, firms with low SA index and those in less competitive industries.     

吃喝腐败、税收寻租与企业成长——来自中国企业的经验证据

税收的弹性空间使低成长率的企业能够借助吃喝腐败进行税收寻租以促进其成长,这破坏了公平的市场竞争环境,导致了资源误置。本文运用2005年世界银行对中国企业的调查数据,分析吃喝腐败和税负对企业成长的影响。分位数回归结果发现,重税负阻碍企业成长,吃喝腐败有助于缓解企业税负对其成长的不利因素。但这种润滑剂作用主要体现于低成长的企业,使其能在权力庇佑下继续生存,对高成长的企业这种作用并不明显。在运用工具变量解决税收的内生性问题和一系列的稳健性检验后,以上结论仍然成立。进一步根据企业规模和制度质量进行的分样本研究发现,吃喝腐败缓解企业税负以促进其成长的润滑剂作用在中小企业和制度质量低的地区表现得更为突出。因此,结构性减税与建立公平的市场竞争环境是释放企业成长空间的关键。     

中国企业年金企业所得税优惠政策的决定因素——基于省际数据的实证研究

基于省际样本实证分析中国企业年金税收优惠政策的影响因素。选择2000年中央在辽宁省试行4％企业所得税优惠之后,至2008年财政部统一全国4％的税优期间,发布地方性企业年金税优政策的省级行政区为样本。以各地方企业所得税优惠比例为因变量,以各地方发布企业年金税优政策上一年度,相对于辽宁省的企业所得税收入、企业与机关单位职工人均退休金差距、企业职工人均退休金为解释变量,分别使用排序选择模型和二元选择模型进行8次估计。结果显示：①企业与机关单位职工人均退休金差距对企业年金企业所得税优惠政策有显著影响,差距越大,税优比例越大;②中央试点政策具有重要标杆作用;③企业职工收入差距是企业年金税优政策的重要制约因素。建议中央明确企业年金的替代率目标,恢复省级政府税优政策的自主权,增加4％-8．3％不同水平的税优试点。     

Tax enforcement and corporate employment: Evidence from a quasi-natural experiment in China

This study investigates how tax enforcement affects corporate employment in China. We utilize the merger of the State Tax Bureau and Local Tax Bureaus as a quasi-natural experiment and adopt a difference-in-differences framework to identify causality. The results show that tougher tax enforcement has a significant and negative effect on corporate employment and that this effect is more pronounced for firms with higher labor intensity, greater financial constraints, more severe labor market frictions, a lower initial tax rate, lower tax transfer ability, and greater credit market imperfections. Further, the mechanism tests demonstrate that tougher tax enforcement leads to increases in the effective income tax rate, cash holdings, and the cash flow sensitivity of real investment but decreases in accounts receivable and dividend payments. These results are consistent with the liquidity constraints channel. In addition, we exclude several alternative explanations and conduct a series of robustness checks. Overall, our findings indicate that corporate tax enforcement has large effects on the local labor demand, which provides some useful insights for local governments to stabilize employment during the COVID-19 pandemic.     

Economic Effects of Taxes on Exports of Palm Oil Products

In an effort to control increases in the prices of certain tradable commodities in recent years, the Indonesian government has experimented with a variety of policy interventions. Palm oil is important both as an export commodity and for household consumption in the form of cooking oil. We examine a palm oil export tax policy that ran from September 1994 through June 1997. We find that the taxes did reduce the domestic prices of palm oil products, and we estimate their effects on the distribution of income within Indonesia. Notably, we find that they actually reduced revenues of the government, and lowered profits for palm oil refiners. We also examine the efficiency effects and other aspects of the taxes. Finally, we discuss more drastic export restraints imposed more recently by the government during the economic crisis.