ODI与我国企业所得税激励政策

税收激励是促进我国对外直接投资发展的重要税收政策手段。但是我国的现行对外直接投资企业所得税激励政策存在诸多问题,如政策导向性弱、避免国际重复征税的措施不健全等。在借鉴国外激励对外直接投资的税收政策基础上,我们提出明确ODI税收政策的区域和产业导向,进一步完善消除国际双重征税的措施等建议,以优化我国对外直接投资企业所得税激励政策。     

税收优惠因抵免制而失效?——基于美国对华直接投资的研究

在国际直接投资研究领域,人们普遍认为,当母国对来源于外国的所得实行抵免制以避免国际重复课税时,东道国对外资企业的税收优惠往往转化为母国政府的财政收入,母国的投资者无法获得东道国给予的税收优惠.通过对1990～2004年实行抵克制的美国及实行豁免制和饶让抵免制的其它西方发达国家在华直接投资进行比较,未发现美国与其它西方发达国家在华直接投资的积极性存在显著差异.由于美国对该国投资者给予税收递延,使得投资者依然能够获得东道国的税收优惠,美国实行的抵免制并未阻碍该国投资者的在华投资热情.     

两法合并对FDI的影响分析

两法合并解决了因企业"身份"不同而享受不同税收待遇的问题,为各类企业创造了一个公平竞争的税收法制环境。新企业所得税法对FDI税收政策的变化,导致了外商来华投资的方式也发生了变化。这表明两法合并对FDI会产生短期影响,至于是否会改变长期发展态势是由综合因素体系决定的,因此,今后要注意防范税收累积效应。     

Incentive Targeting, Influence Peddling, and Foreign Direct Investment

We expand the traditional tax incentive redundancy argument by investigating the implications of allocating incentives primarily to firms that would have invested even in the absence of special tax treatment. Incorporating government revenue constraints, pliable tax officials, endogenous tax liabilities, and firms with heterogeneous before-tax returns, we show that tax incentives, if given to the wrong firms, are not only ineffective in stimulating FDI, but result in a form of tax shifting and may reduce FDI. Data from countries of the former Eastern Bloc suggests that tax incentive schemes have significantly negative impacts on FDI in countries that poorly target firms.     

The impact of tax incentives on foreign direct investment in China

Scholes and Wolfson 1989, Scholes and Wolfson 1992) argue that tax rules jointly influence investment decisions and organizational form. The present research uses Chinese data to test these assertions. Specifically, our study investigates whether (1) the creation of special tax incentive zones is an effective tax policy for China to induce new foreign direct investment (FDI) into specific regions, and (2) changes in the tax rules influence the particular form of foreign direct investment selected: equity joint ventures, contractual joint ventures, and wholly foreign-owned enterprises. Our results indicate that tax incentives are effective in attracting FDI to China, and moreover, influence the selection of a particular form of FDI. One limitation of our study is that we were unable to completely control for the correlated-omitted-variable problem.     

Host-country governance, tax treaties and US direct investment abroad

We investigate how the quality of the host-country governance and a bilateral US income tax treaty affect the rates of return that US companies require on their foreign direct investment (FDI). Using indexes of corruption and political instability, we find that poor governance causes the companies to require significantly higher rates of return. This lends support to earlier authors who have concluded that poor governance discourages both local investment and inward FDI. After accounting for the quality of host-country governance, however, no evidence could be found that an income tax treaty has any effect on the required rates of return.      

The effectiveness of tax incentives in attracting investment: panel data evidence from the CFA Franc zone

In this paper we investigate to what extent tax incentives are effective in attracting investment in Sub-Saharan Africa. We test the neo-classical investment theory prediction that tax incentives, by lowering the user cost of capital, raise investment. Next to tax incentives, we also estimate the impact on investment of other investment climate variables that are under direct control of the government, such as the transparency and complexity of the tax system, and the legal protection of foreign investors. In developing countries these variables might be as important as or even more important than the tax variables themselves.     

Convergence of accounting standards and foreign direct investment

Since the development of the eclectic paradigm by Dunning (1977, 1988, 1993), many studies have investigated different forms of location advantages that attract foreign direct investment (FDI). In this study, we consider accounting standards as a component of the institutional infrastructure of a location and hypothesize that the convergence of domestic and International Financial Reporting Standards (IFRS) promotes FDI as it reduces information processing costs for foreign investors.² We also hypothesize that the effect of reduced information costs is stronger for partner countries whose accounting systems showed greater pre-convergence differences because they magnify the facilitating role of accounting standard convergence for FDI. Using bilateral FDI data from 30 OECD countries between 2000 and 2005, we find evidence generally consistent with these hypotheses.     

Taxes and production: The case of Pakistan

This paper investigates the effectiveness of investment incentives and corporate income taxes in influencing production and investment decisions in the Pakistani wearing apparel and leather products industries. Three tax instruments are considered: the corporate income tax (CIT), the investment tax credit (ITC), and the capital cost allowance (CCA).The results show that since there are significant capital adjustment costs, it is important to distinguish between the short, intermediate, and long-run effects associated with the tax instruments. Production decisions are relatively more responsive to changes in the ITC rate compared to changes in either CCA or CIT rates in each run. However, only in the long run for the apparel industry are the ITC and CCA rates cost effective in stimulating investment. The CIT is never cost effective. Thus targeted instruments outperform the general CIT instrument. In addition, although the incentive to invest is enhanced, there is little effect on output. Therefore, tax incentives essentially make production techniques more capital intensive.     

Evaluating Tax Policy for Location Decisions

We consider the impact of taxation when investors face a discrete choice between two or more mutually exclusive projects; in particular we consider the location choice of multinationals. Such choices depend on an effective average tax rate. We propose a precise measure of this rate, which is shown to be equal to a weighted average of an effective marginal tax rate and an adjusted statutory tax rate, where the weights depend on the profitability of the investment. Estimates of the distribution of this measure are presented and compared for domestic and international investment in the USA, France, Germany and the UK. We analyse the impact of harmonising corporate tax rates in Europe on incentives to locate in France, Germany and the UK.     

税收优惠政策对吸引外国直接投资的作用初探

一直以来,税收理论界对于税收优惠政策的实际经济效应和其吸引外国直接投资(FDI)的有效性始终都存有争议.本文分析了税收优惠政策的有效性以及各种税收优惠手段的实施效果,为我国适当运用税收优惠政策吸引FDI提出了相关建议.     

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。     

税收优惠对外商投资影响的研究综述

税收优惠是各国政府用来吸引外商投资的常用手段。但是,税收优惠如何影响外商投资历来就是一个充满争议的话题。早期国际上关于税收优惠对外商投资影响的经典理论主要有庇古的福利经济学理论、“双缺口”模型和邓肯的国际折衷理论,而近来也有不少国内外学者分别从区位选择、融资来源、投资类型和投资形式等角度论证了税收优惠的作用。     

IFRS adoption in China and foreign institutional investments

We examine the effectiveness of China’s IFRS adoption from the perspective of an important set of financial report users, foreign institutional investors. We find that foreign institutional investment does not increase after China’s IFRS adoption, and some evidence that it actually declines, particularly among firms with weaker incentives to credibly implement IFRS, or with greater ability to manipulate IFRS’s fair value provisions. We also find that the association between earnings and returns generally declines after IFRS adoption, consistent with reduced earnings quality. In addition, we find that foreign institutional investors’ returns decrease after China’s IFRS adoption. Finally, the decline in foreign institutional investment is greater among investors from countries with weak institutions that have also adopted IFRS. Taken together, our evidence suggests that the weak institutional infrastructure in China’s transitional economy impairs IFRS’s intended goal of attracting institutional investment through improved financial reporting quality. Further, financial information users’ home country institutions and IFRS adoption experience affect the effectiveness of IFRS adoption.     

Total Factor Productivity,Foreign Direct Investment,and Entry Barriers in the Chinese Automotive Industry

We explore three questions on foreign direct investment (FDI): (1) What are the differences in entry barriers for foreign, public, and private investors? (2) What are the effects of past productivity levels on future foreign direct investment (FDI) decisions? (3) What is the effect of equity structure on future total factor productivity (TFP) levels? The empirical results based on a monopolistic competition model and using a firm-level data set from the Chinese automobile industry suggest that foreign investors face higher entry barriers and react stronger to past TFP levels. FDI is also found to improve future TFP more than other forms of investment. Finally, World Trade Organization (WTO) accession is found to reduce entry barriers for foreign and domestic private investors while increasing entry barriers for public investors.     

一个有远见的税收制度应当关注未来的税基——特朗普新税法的成本分析及政策建议

20世纪50年代以来,美国企业所得税税率持续下降,政府税收收入也处于较低水平。2017年,特朗普新税法的实施大幅度降低了企业所得税税率,导致政府税收损失远超预期。然而,新税法实施后,美国企业投资和长期经济增长并没有明显改善。本文认为,一个国家经济效率主要取决于税基而非税率,美国政府应通过税收制度改革,增加对企业投资和研发投入的激励,从而扩大税基,实现经济的长期改善。     

The tax-induced holding periods of real estate Investors: Theory and empirical evidence

This article reexamines holding period decisions in real estate investment. It develops and empirically tests a holding period model recognizing not only taxes but also refinancing and investor-specific determinants. Based on a sample of over 1,000 real estate transactions with observed holding periods, the results of our tests support the conclusion that investors' consumption and investment preferences and prevailing market interest rates are more important than tax issues in determining the holding periods of real estate investors.     

Taxing Multinationals

This paper analyzes the effects of tax policy on the strategic choices of multinationals and on national welfare. Contrary to existing theory, in the absence of foreign taxation, deferral of home-country taxation until earnings on outbound FDI are repatriated is generally superior to including those earnings in current income. This holds even if the home country taxes domestic investment less generously. This is also generally superior to exempting foreign income. Foreign taxes permit foreign governments to capture some of the pre-tax economic rent from the home-country FDI; this reduces the benefit to the home country of more generous taxation of outbound FDI.     

新企业所得税制对我国引进外资的影响及效应研究

本文通过对外商投资规模、产业结构、区域结构等方面的数据分析,研究2008年实施的新企业所得税制,相对减少外商投资企业税收优惠背景下,新企业所得税制实施对引进外资的影响及其效应。其结论是新企业所得税法实施后,虽然外商投资于中国境内的企业数量、绝对规模并未减少,且有一定增长趋势,但引资规模的增长幅度下降;投资于第一产业的企业数量和金额在三大产业中所占比重一直极低,投资于第二产业比例逐渐降低,投资于第三产业比例相对提高,对引导外商进入高新技术行业和基础设施建设激励不够明显。进而提出适度延长中西部地区企业所得税税收优惠期并加大优惠力度,对高新技术企业等实施一定期限的所得税免税优惠,适度延长基础设施建设的减免税期限或改变优惠方式等完善企业所得税制度的建议。     

Crowdfunding tax incentives in Europe: a comparative analysis

ABSTRACT

Some European countries offer tax incentive schemes to investors and companies in crowdfunding. On one hand, they could be seen as a tool to reduce the system’s dependence on banks and increase the availability of credit for start-ups and Small and Medium Enterprises (SMEs). On the other hand, there is the counterweight of disadvantages that investors may face by investing in crowdfunding (i.e. complex and incomplete laws, and weak protection). This paper is primarily intended as a primer on the use of tax incentives for crowdfunding in Europe. In this study, we first examine the implementation of tax incentive schemes in the United Kingdom, France, Italy, Spain, and Belgium. Then, we analyse and compare the characteristics of such schemes along three dimensions: the incentives structure; the business characteristics; and the type of investor. We find that tax incentive schemes for crowdfunding vary widely in their form and other features of their design. Moreover, the most used forms of tax incentives are those that provide for an up-front tax credit on the amount invested in early-stage ventures. These incentives have an immediate effect on the annual income tax of the investor. A central implication is that the more tax incentive schemes are properly designed and tailored for crowdfunders, the more investors, start-ups and other firms with low liquidity could use crowdfunding as a source of funding.