The determinants of thinly capitalized tax avoidance structures: Evidence from Australian firms

This paper examines the determinants of thinly capitalized structures of publicly-listed Australian firms. Based on a hand-collected sample of 203 publicly-listed Australian firms over the 2006–2009 period (812 firm-years), our regression results indicate that the thin capitalization position of firms is significantly and positively associated with multinationality, tax haven utilization, withholding taxes and tax uncertainty. Multinationality and the use of tax havens are, in particular, strongly associated with thin capitalization. Our additional regression results provide evidence that shows that corporate governance monitoring mechanisms relating to board of director independence, institutional ownership and big-4 auditor utilization are significantly negatively associated with firms adopting thinly capitalized tax avoidance structures.     

Determinants of tax haven utilization: evidence from Australian firms

This paper examines the major determinants of tax haven utilization based on a sample of 200 publicly listed Australian firms, over the 2006–2010 period (1,000 firm‐years). Our regression results show that variables relating to transfer pricing, intangible assets, an interaction term between transfer pricing and intangible assets, withholding taxes, performance‐based management remuneration and multinationality are positively associated with tax haven utilization. We also find that corporate governance structures are negatively associated with tax haven utilization. The magnitude and significance of the regression coefficients indicate that transfer pricing, withholding taxes, intangible assets, an interaction term between transfer pricing and intangible assets, corporate governance and multinationality are the most important drivers of tax haven utilization.     

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.     

在华外企的反避税审计策略研究

通过对转让定价、资本弱化、利用避税地以及选择公司组织形式等在华外企常用的避税方式和手段进行剖析,说明在以后相当长的时期内,应当将长期亏损、长期微利或跳跃性赢利却不断扩大经营规模的外资企业作为反避税审计的重点对象,并在提升立法层次、建立跨国合作机制、完善反转让定价税制、制定避税地和资本弱化税法、加强对电子商务税收问题的研究等方面来完善反避税审计策略。     

Using Financial Accounting Data to Examine the Effect of Foreign Operations Located in Tax Havens and Other Countries on U.S. Multinational Firms' Tax Rates

This paper investigates the effect tax havens and other foreign jurisdictions have on the income tax rates of multinational firms based in the United States. We develop a new regression methodology using financial accounting data to estimate the average worldwide, federal, and foreign tax rates on worldwide, federal, and foreign pretax book income for a large sample of U.S. firms with and without tax haven operations. We find that on average U.S. firms that disclosed material operations in at least one tax haven country have a worldwide tax burden on worldwide income that is approximately 1.5 percentage points lower than firms without operations in at least one tax haven country. Our results also show that U.S. firms face a 4.4% current federal tax rate on foreign income whether or not they have tax haven operations. Finally, we find that U.S. firms with operations in some tax haven countries have higher federal tax rates on foreign income than other firms. This result suggests that in some cases, tax haven operations may increase U.S. tax collections at the expense of foreign country tax collections.     

The influence of international taxation structures on corporate financial disclosure patterns

This paper investigates the extent of financial instrument disclosures (FIDs) within the annual reports of Australian listed extractive resource companies over a 4-year longitudinal period (2003–2006) and its association with international tax characteristics. Statistical analysis shows that thin capitalisation structures and withholding taxes are positively and significantly associated with disclosure patterns. In contrast, the occurrence of foreign sourced income and tax haven links are significantly negatively associated with FID patterns. These findings demonstrate that international tax structures can influence corporate disclosure patterns. This paper contributes to an understanding of the extent, trends and rationale behind resource firms’ financial instrument disclosure practices in Australia.     

Customer–supplier relationships and corporate tax avoidance

We investigate whether firms in close customer–supplier relationships are better able to identify and implement tax avoidance strategies via supply chains. Consistent with our prediction, we find that both principal customers and their dependent suppliers avoid more taxes than other firms. Further analysis suggests that principal customers and dependent suppliers likely engage in tax strategies involving shifting profits to tax haven subsidiaries. Moreover, tax benefits appear to explain both principal customer firms’ and dependent supplier firms’ organizational decisions. Overall, our study provides evidence of the importance of tax avoidance as a source of gains from these relationships.     

Incentives for corporate tax planning and reporting: Empirical evidence from Australia

This study extends prior research on the willingness of firms to significantly decrease their corporate taxes. It specifically examines the associations between corporate tax avoidance and the reported significant uncertainty of a firm’s tax position, the tax expertise and tax affiliations of its directors, and the performance-based remuneration incentives of its key management personnel. Based on a dataset of 200 publicly listed Australian firms over the 2006–2010 period (1000 firm years), we find that the reported uncertainty of a firm’s tax position, the tax expertise of its directors, and the performance-based remuneration incentives of its key management personnel are significantly positively associated with tax avoidance. Conversely, firms with board members who have at least one tax-related affiliation are significantly negatively associated with tax avoidance.     

避税地避税及其防范

本文在对避税地的产生和发展,以及避税地对各国经济的危害进行深入研究并对世界各国应对避税地的措施进行比较分析的基础上,借鉴国际上的成功经验,对我国目前的跨国企业避税问题进行深入分析,提出了我国税制应对避税地的政策建议和税收征管上的改进措施。     

打击“避税天堂”国际准则的主要内容

本文以有关打击避税天堂的国际准则为主线,在理解和分析避税天堂的含义和危害的基础上,指出保障税制透明度和进行税务信息分享是打击避税天堂的国际准则中最重要的内容。     

Public Pressure and Corporate Tax Behavior

We use a shock to the public scrutiny of firm subsidiary locations to investigate whether that scrutiny leads to changes in firms’ disclosure and corporate tax avoidance behavior. ActionAid International, a nonprofit activist group, levied public pressure on noncompliant U.K. firms in the FTSE 100 to comply with a rule requiring U.K. firms to disclose the location of all of their subsidiaries. We use this setting to examine whether the public pressure led scrutinized firms to increase their subsidiary disclosure, decrease tax avoidance, and reduce the use of subsidiaries in tax haven countries compared to other firms in the FTSE 100 not affected by the public pressure. The evidence suggests that the public scrutiny sufficiently changed the costs and benefits of tax avoidance such that tax expense increased for scrutinized firms. The results suggest that public pressure from outside activist groups can exert a significant influence on the behavior of large, publicly traded firms. Our findings extend prior research that has had little success documenting an empirical relation between public scrutiny of tax avoidance and firm behavior.     

Organizational capital,corporate tax avoidance,and firm value

We show that firms with higher levels of organizational capital (OC) exhibit higher levels of tax avoidance and that shareholders view tax avoidance of high OC firms as value-enhancing. We also show that the OC-tax avoidance relation mainly manifests in firms with good internal governance and information environment and in firms that face tight financial constraints. In addition, we document that tax avoidance by high OC firms increases future cash flow and that high OC firms are more likely to invest in tax haven subsidiaries. Overall, our evidence suggests that OC enhances firms' tax efficiency.     

Spillover effects of VAT Self-enforcement properties: Evidence based on the replacement of business tax with VAT reform

In accordance with the purchasing tax-deduction method and the receipt-based value added tax (VAT) system, the same transaction can be recorded by two firms, which creates self-enforcement properties, thereby restraining tax avoidance. Using the Replacement of Business Tax with VAT reform in China, this paper adopts a difference-in-differences design to investigate the spillover effects of VAT self-enforcement properties on corporate income tax avoidance by manually collating information about suppliers/clients of listed firms. As the listed firms' suppliers/clients switch from paying business tax to paying VAT, there is a striking decline in their corporate income tax avoidance behavior. This effect is pronounced in firms with closer upstream and downstream correlations, higher information complexity and stronger incentives for tax avoidance.     

Ownership Concentration,State Ownership,and Effective Tax Rates: Evidence from China’s Listed Firms*

This paper examines the effect of ownership concentration and state ownership on the tax reporting practices of China’s publicly listed firms. I argue that ownership concentration and state ownership are important for tax reporting practices in China because listed firms have high ownership concentrations and high levels of state ownership. Using a sample of 758 listed Chinese firms over the 1998–2008 time period, I find that firms with concentrated share ownership have lower effective tax rates. I also find that firms whose largest shareholders are government‐related have higher effective tax rates compared to firms whose largest shareholders are nongovernment related. In other words, the nature of the largest shareholder (government vs. nongovernment) matters. I also show that ownership‐concentrated firms are able to achieve preferential statutory tax rates compared to firms with low ownership concentration regardless of the identity of the largest shareholder.     

Corporate tax avoidance: data truncation and loss firms

Loss firms are an economically significant and growing segment of the population of publicly traded corporations. Relatively little is known about the tax positions of loss firms because the firms are typically dropped from tax avoidance studies. We develop a new measure of corporate cash tax avoidance that is meaningful for all observations and reflects the extent to which a firm is tax-favored. We examine the extent to which inferences about corporate tax avoidance over the past twenty-seven years change when we examine the full population of firms, as opposed to a profitable and/or taxable subsample. In contrast to prior research findings, our results suggest that on average firms are tax-disfavored, by which we mean cash taxes paid exceed the product of the firm’s pre-tax book income and the statutory tax rate. In addition, many industries that appear to be tax-favored in profitable subsamples are tax-disfavored when the entire population is examined. We also find that the extent to which firms are tax-disfavored is increasing over time, and that domestic firms are more tax-disfavored than multinationals.     

Exploring the role Delaware plays as a domestic tax haven

We examine whether Delaware is a domestic tax haven. We find that taxes play an economically important role in determining whether U.S. firms locate subsidiaries in Delaware and that a Delaware-based state tax avoidance strategy lowers state effective tax rates by between 0.7 and 1.1 percentage points, on average. The tax savings represent a 15–24% decrease in the state income tax burden and translate to an increase in net income of 1.04–1.47%. However, we find that the tax benefits of Delaware tax strategies are diminishing over time in response to initiatives by state governments to limit multistate tax avoidance.     

安全港规则及其在我国的适用

针对纳税人利用资本弱化进行避税的问题,从20世纪80年代起,许多发达国家通过建立资本弱化税制来规制这种避税行为。发达国家防止资本弱化避税的通行做法主要是采用安全港规则和正常交易规则两种。在经济全球化的条件下,我国的资本弱化避税问题同样不可避免。因此,借鉴防止资本弱化避税的安全港规则在发达国家的应用实践,对建立我国的资本弱化税制是十分必要的。     

Determinants of Financial Ratio Disclosure Patterns of Australian Listed Extractive Companies

We investigate the disclosure patterns of Financial Ratios (FRDs) within the annual reports of 111 Australian listed resource companies over the period 2002 to 2006. Disclosure of financial ratio information increased over this period with a significant increase in disclosures recorded in the first full‐year annual report prepared following adoption of IFRS. The results of logistic regression analysis demonstrate that income tax and firm size are factors that are significantly associated with financial ratio disclosures. This study contributes to an understanding of the extent, trends and rationale behind resource firms’ financial ratio disclosure practices in Australia.     

税收规避与财务报告成本的权衡研究——来自中国2008年所得税改革的证据

本文以我国2008年所得税改革为契机,借鉴Shackelford和Shevlin(2001)的税与非税因素权衡模型,实证考察有减税预期的上市公司在税收规避中是否权衡了财务报告成本。本文发现,有减税预期的公司存在将减税之前期间的利润推迟确认到未来低所得税率期间的盈余管理行为,且为避免这一行为过于明显而遭致惩罚,利润跨期转移的期间宽度较长。但有着高财务报告成本的公司明显降低了这一跨期利润转移的动机。研究证实了我国上市公司在税收规避决策中权衡了税与财务报告成本。研究结论有助于进一步丰富盈余管理文献,对当前我国税收制度改革具有一定参考意义。     

Determinants of transfer pricing aggressiveness: Empirical evidence from Australian firms

This study examines the major determinants of transfer pricing aggressiveness. Based on a hand-collected sample of 183 publicly-listed Australian firms for the 2009 year, our regression results show that firm size, profitability, leverage, intangible assets, and multinationality are significantly positively associated with transfer pricing aggressiveness after controlling for industry-sector effects. Our additional regression results also indicate that firms augment their transfer pricing aggressiveness through the joint effects of intangible assets and multinationality.