Firm-specific forward-looking effective tax rates

This paper computes effective (marginal and average) tax rates that account for bilateral aspects of taxation and, therefore, vary across country-pairs and years. These tax rates serve to estimate the impact of corporate taxation on outbound stocks of bilateral foreign direct investment (FDI) among OECD countries between 1991 and 2002. The findings indicate that outbound FDI is positively related to the parent and host country tax burden and negatively associated with bilateral effective tax rates. Relying only on unilateral (country and time variant) rather than on both unilateral and bilateral (country-pair and time variant) effective tax rates leads to biased estimates of the impact of corporate taxation on FDI.     

Bilateral effective tax rates and foreign direct investment

This paper computes effective (marginal and average) tax rates that account for bilateral aspects of taxation and, therefore, vary across country-pairs and years. These tax rates serve to estimate the impact of corporate taxation on outbound stocks of bilateral foreign direct investment (FDI) among OECD countries between 1991 and 2002. The findings indicate that outbound FDI is positively related to the parent and host country tax burden and negatively associated with bilateral effective tax rates. Relying only on unilateral (country and time variant) rather than on both unilateral and bilateral (country-pair and time variant) effective tax rates leads to biased estimates of the impact of corporate taxation on FDI.     

Do Taxes Matter for Foreign Direct Investment?

The tax sensitivity of foreign direct investment (FDI) has importantpolicy implications. If FDI is not responsive to taxation, thenit may be an appropriate target for taxation by the host country.This question is examined for Mexico by estimating the responseof FDI from retained earnings and transfers from abroad to thetax regimes in Mexico and the home country, the credit statusof multinationals, country risk factors, and regulatory andtrade regimes in Mexico. FDI in Mexico is found to be sensitiveto the tax regimes in Mexico and the United States, the creditstatus of multinationals, country credit ratings, and the regulatoryenvironment. Thus Mexico's current policies to dismantle regulationsand employ a tax system competitive with the United States areexpected to have salutory effects on FDI in Mexico.     

Multiple taxes and alternative forms of FDI: evidence from cross-border acquisitions

This paper explores the role of tax instruments in affecting foreign direct investment (FDI), paying particular attention on their effect on two forms of FDI strategy, ‘horizontal’ and ‘vertical’. Applying a decomposition of FDI strategies to the universe of cross-border mergers (the dominant form of FDI) over the period 1999–2010, it emerges that taxes have a much more nuanced effect on FDI than frequently suggested; while corporate taxes affect FDI negatively, the tax elasticity varies depending on the FDI strategy (with vertical FDI being in general more responsive), the exact measure of taxation, and international tax considerations (double taxation, withholding taxes). Sales taxes also affect FDI, but only horizontally.     

Earnings,institutional investors,tax avoidance,and firm value: Evidence from Taiwan

This study examines the valuation of earnings from China and Taiwan by foreign and domestic institutional investors across a sample of Taiwanese electronics firms. We further compare the valuation of firm earnings reported in tax havens and non-tax havens, and whether these firms have changed tax avoidance activities since 2004 when the Taiwanese government enacted stricter auditing of transfer pricing regulation.Our findings show that both operating income from the home country and investment income are positively associated with firm value. Operating income from China, however, is not significantly related to firm value when institutional ownership of the firm exceeds fifty percent. This result indicates that operating income is valued differently, depending on the location from which the income was generated. Non-operating income enhances firm value regardless of the revenue source. We also report that foreign institutional investors favor operating income from domestic and investment sources over earnings generated from non-domestic sources and other non-operating income. Furthermore, our results suggest that firms rearrange reported profits from subsidiaries located in tax havens to affiliates in other countries following the transfer pricing audit guide Taiwan implemented in 2004. Results also indicate firms may have been shifting profits to other low-tax-rate countries, or to countries which do not require firms to pay taxes, even if they are not doing business in that country.     

Profit shifting in the EU: evidence from Germany

The paper considers profit shifting behavior using data on German inbound and outbound FDI. It finds an empirical correlation between the home country tax rate of a parent and the net of tax profitability of its German affiliate that is consistent with profit shifting behavior. For profitable affiliates that are directly owned by a foreign investor the evidence suggests that a 10-percentage point increase in the parent’s home country tax rate leads to roughly half a percentage point increase in the profitability of the German subsidiary. On the outbound side of German FDI, the data provides some evidence that tax rate changes in the host country lead to a stronger change in after-tax profitability for affiliates that are wholly owned, which may reflect the larger flexibility of these firms in carrying out tax minimizing behavior without interference of minority owners. The hospitality and support by the Deutsche Bundesbank Research Center is gratefully acknowledged. I thank Oliver Busch, Michael P. Devereux, Ruud de Mooij, Chris Heady, Beatrix Stejskal-Passler, an anonymous referee, and participants of the IFS/ETPF conference 2006 for excellent comments and suggestions. All remaining errors are mine.     

Optimal Capital Income Taxes and Capital Controls in Small Open Economies

This paper studies the optimal taxation of capital income in a simplemodel of a small open economy where domestic residents can evade taxeson their foreign investment income. The national government can onlytax domestic capital income and can impose capital controls, whichhowever absorb real resources. The design of optimal policy in thismodel depends on the revenue needs of the government. For relativelylow levels of government expenditures, it turns out that the countrydoes not levy capital income taxes but may restrict capital exports.Otherwise, the country taxes domestic capital income and sets capitalcontrols such that capital exports are driven to zero, at an optimum.In contrast to other models with capital controls it turns out thatthis policy can lead to underinvestment in domestic capital.JEL Classification Number: E 62, F 41, H 21     

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.     

An empirical study of the impact of corporate taxation on the global allocation of foreign direct investment: a broad tax attractiveness index approach

The question of whether a country’s corporate tax regime has a significant influence on the level of foreign direct investment (FDI) into that country is an important consideration in the design of national tax policy. This is especially relevant today in view of the recent increase in the global mobility of capital and subsequent increase in the importance of FDI to nations’ economies. Although several prior quantitative studies have investigated the link between taxation and FDI, they have tended to be restricted in geographical scope and in their measure of taxation.This study constructs indices of “corporate tax attractiveness” for selected countries and then analyses the relationship between the indices and measures of the flow of FDI into those countries. The indices are constructed by obtaining evaluations from international investors and taxation experts on the various attributes of the tax systems of those selected countries. A significant positive relationship was found to exist between the indices and measures of FDI inflows, and between individual tax system attributes and those inflows, thus adding support to the supposition that host country corporate taxation influences the size of FDI inflows.     

Do tax sparing agreements contribute to the attraction of FDI in developing countries?

Measuring the effects of taxation on FDI in developing countries requires consideration of the tax sparing provision. This provision signed between developed and developing countries protects host country fiscal incentives for FDI. This paper estimates the impact of tax sparing provisions on Japanese outbound FDI between 1989 and 2000. We find evidence that the tax sparing provision influences positively the location of Japanese FDI, even after having taken into account reversal causality. JEL Classification F23 · H25 · H32 We Thank Michael Devereux, Edward Graham, Robert Lipsey, David Margolis, Claudia Rivas, Deborah Swenson, anonymous referees and seminar participants at the Franco-Korean conference in Seoul, and at the Western Economic Association conference in Vancouver for helpful discussions.     

Tax Competition and Foreign Capital

This paper derives welfare equivalence of double taxation rules in a tax competition model with discriminatory home taxes and the ability to finance subsidiary operations with host country capital. For a more general model, we provide sufficient conditions on the number of host sectors and factors that support double-tax-rule equivalence. Examples violating these conditions help identify economic factors under which a home country has strict preferences over double taxation rules. If the home tax rate can influence host factor prices, the home country weakly prefers deductions over credits as in the pure-home-equity financing case.     

Currency Denomination of Intercompany Debt and Multinational Taxes

For multinational companies (MNCs) with foreign subsidiaries, the currency denomination of intercompany debt can have important effects on both taxes and financial statements. This paper analyzes the choice between an intercompany loan denominated in the home currency and one denominated in the subsidiary's functional currency. Using U.S. rules for financial accounting and taxes, the author demonstrates the expected impact of the loan's currency denomination on the expected level and variability of an MNCs overall taxes in the case where it has excess foreign tax credits.
The author's analysis shows that the foreign currency loan denomination leads to lower expected tax if the foreign withholding tax rate on interest is higher than the parent's home income tax rate. At the same time, the parent currency denomination leads to lower expected taxes if the parent's home income tax rate is higher than the foreign withholding tax rate on interest. Moreover, if an MNCs excess foreign tax credits are attributable to the subsidiary, the foreign currency loan denomination leads to lower variability in overall taxes. But in cases where the excess foreign tax credits arise from other foreign operations, the parent currency denomination leads to lower variability of overall tax.     

Australia's home bias and cross border taxation

The paper examines the impact of cross border taxation on Australia's free float home bias. The paper controls for various sources of home bias including familiarity, explicit cost, diversification motives and governance issues when examining the impact of cross border tax variables. In our sample of 44 foreign countries where Australia invests over the period 2001 to 2009, about 66% (82%) withhold taxes on realized capital gains (dividends) of foreign investors. A tax credit variable for foreign taxes paid on dividends is constructed and found to be statistically significant in reducing home bias.     

Real Effects of Accounting Rules: Evidence from Multinational Firms’ Investment Location and Profit Repatriation Decisions

We analyze survey responses from nearly 600 tax executives to better understand corporate decisions about real investment location and profit repatriation. Our evidence indicates that avoiding financial accounting income tax expense is as important as avoiding cash income taxes when corporations decide where to locate operations and whether to repatriate foreign earnings. This result is important in light of the recent research about whether financial accounting affects investment and in light of the decades of research on foreign investment that examines the role of cash income taxes but heretofore has not investigated the importance of financial reporting effects. Our analysis suggests that financial reporting is an important factor to be considered in the policy debates focused on bringing investment to the United States.     

Profitability Life Cycle of Foreign Direct Investment: Application to the Czech Republic

The decisions of foreign direct investors are profit-seeking, so deterioration in the primary income balance of the current account is observed. We estimate the common profitability profile of foreign direct investment (FDI) on a panel of mostly European countries in the period from 1990 to 2015. The FDI profitability life cycle has a non-linear time profile with duration of 16 years. Maximum profitability is reached in the sixth year after the initial investment. We then construct three scenarios for the evolution of total FDI earnings in the Czech Republic depending on the future FDI inflows (changing FDI stock) assumed.     

The location of financial sector FDI: Tax and regulation policy

This paper analyzes how corporate taxation and regulatory requirements affect the location of financial sector FDI. We use novel information on new financial services entities established by multinational firms in 83 host countries. We find a negative effect of host country taxes on the probability of choosing a particular host location. We can also confirm a significant influence of the regulatory environment. For example, stricter (equity) capital requirements negatively affect location probabilities. Our empirical approach allows us to provide new insight in how a policy measure of a given country affects other countries by estimating cross-country tax and regulation elasticities.     

Firms’ share price reactions to The American Jobs Creation Act

The American Jobs Creation Act of 2004 permitted a one-time 85% dividend received deduction for repatriated foreign earnings. A stated purpose of this legislation was to permit companies to access foreign earnings domestically that would have been too costly previously because of repatriation taxation. Using a portfolio analysis we find that firms with large foreign asset balances experienced significantly positive returns during the legislative window for the Jobs Act, and that these findings also hold for sub-samples that are designated as financially constrained or highly leveraged. These results indicate that the market perceived passage of the Jobs Act as good news for those firms with the need, domestically, for these unrepatriated foreign earnings. We conclude that these findings are supportive of the policy intentions that formed the basis of the temporary reduction in the repatriation taxes.     

The fleeting nature of permanent reinvestment: Accounting for the undistributed earnings of foreign subsidiaries

Over the last decade, an increasing percentage of the profits reported by U.S. corporations were earned by their foreign subsidiaries and retained outside the United States resulting in the deferral of income taxes. The American Jobs Creation Act of 2004 provided a temporary federal tax incentive to remit such earnings, which resulted in the repatriation of $140 billion by the 30 firms comprising the Dow Jones Industrial Average. An analysis of the financial reporting disclosures made by these firms reveals that a tax expense was not fully recognized on a substantial portion of the earnings until repatriation because of an exception for foreign reinvestments deemed to be essentially permanent in duration. The implications of the currently acceptable accounting for undistributed foreign earnings are discussed as well as recommendations to improve the relevancy and reliability of the disclosures required for this exception to comprehensive recognition of deferred taxes.