我国企业对外直接投资涉税问题探析

目前,我国企业走出去主要形式有:一是境外工程承包和劳务输出;二是资本输出(主要指对外直接投资)。本文着重分析了我国对外直接投资的现状和现有对外投资税收政策存在的问题,并提出了完善税收政策的几点建议。     

Effects of Foreign Presence in a Transition Economy: Regional and Industrywide Investments and Firm-Level Exports in Ukrainian Manufacturing

We investigate the effects of regional and industrywide foreign presence and foreign direct investment (FDI) on the export volumes of Ukrainian manufacturing firms using unpublished panel data from 1996-2000. Foreign presence through FDI may have negative competition effects on domestic firms' performance; at the same time, domestic firms' productivity may be increased by technology transfer or training and demonstration effects. From a Cournot competition model that includes negative competition and positive technology spillover effects, we hypothesize that foreign presence and FDI might positively affect domestic firms' output and exports. Our estimation results support these hypotheses, suggesting in particular that large firms and durable goods producers benefit most from foreign presence and investments.     

Analysis of foreign investment impact on the dynamics of national capitalization structure: A computational intelligence approach

Central and Eastern Europe countries are in the political and economic transitional process of merging with the European Union. How has foreign investment already transformed these countries’ economic sectors and how will it affect the national economies in terms of capitalization across economic sectors in the near future? Our prime consideration is portfolio investment impact on the dynamics of respective countries’ capitalization structure in terms of sectorial investment distribution. The proposed method rests on the artificial intelligence approach (neural network method), which is targeted to grasp non-linear dynamics of heterogeneous foreign investment impact on national capitalization structure.     

Foreign direct investment and trade: The case of Vietnam

By making use of a gravity model, this paper examines the impact of FDI on exports, imports and net export of Vietnam. The empirical analysis presented in this paper is based on a recently released panel dataset involving Vietnam's 19 major trading partners for the period 1990-2007. The paper also considers the impact of FDI on trade during three sub-periods: the pre-Asian financial crisis, the post-Asian financial crisis and during the Asian financial crisis period. The empirical analysis reveals that a complementary relationship exists between FDI and exports and FDI and imports. While the impact of FDI on net-exports is insignificant during the full sample period, a significant positive relationship exists between net-exports and FDI in the post-Asian financial crisis period.     

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.     

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.      

税收管辖权原则及其灵活运用

税收管辖权原则包括属地原则和属人原则。美国联邦税制改革总统顾问小组建议美国公司所得税的税收管辖权原则由属人原则转变为属地原则。本文认为,这种转变对我国的税收收入、我国企业的竞争力等影响不是很大,但是,从国际形势和中国当前的宏观经济特点来看,我国有必要对税收管辖权原则进行灵活调整。     

Melting pot or salad bowl: Some evidence from U.S. investments abroad

We estimate the number of foreign-origin persons in the United States classified by their country of origin from census data in 1970, 1980, 1990 and 2000. We find, both in cross-sectional tests and in panel data tests, that the size of the foreign-origin group from a country living in the U.S. is positively correlated with U.S. investments in that country. This national origin bias is strong for direct (FDI) and modest for indirect (equity holdings) investments. The results continue to hold even after controlling for the “fundamentals” hypothesized to affect foreign investments. The other economic geography variables of a country—physical distance from the U.S., race, language and religion—do not seem to affect US investments in that country.     

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.     

The European flying geese: New FDI patterns for the old continent?

This article attempts to apply the flying geese metaphor to emerging foreign direct investment (FDI) patterns in Europe and the Mediterranean. Such a division of labour is at best at a nascent stage, given the overwhelming share of Western Europe in both inward and outward foreign direct investment flows. Because of these imbalances, special attention is to be paid to Central and Eastern Europe’s (CEE) potential, both in the group joining the European Union (EU) in 2004 and the rest of the subregion. For the former, middle-income countries, risks in investment promotion are related to uncertainty brought about by the transition to European Union’s acquis and an eventually too fast increase in production costs. Policy response to that requires a modernisation of both general and specific investment promotion policies, adjusted to the rules of the Union. For the rest of Central and Eastern Europe, the challenge is to adjust to the enlarged European Union and to improve the business and investment environment, in order to capture the foreign direct investment outflows of other European countries searching for optimum labour costs.     

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.     

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.     

外商投资湖南省制造行业的环境效应实证研究

基于湖南省2006～2009年外商直接投资的20个制造业的面板数据,以工业SO2工业废气、工业废水和工业固废四类污染物排放量为被解释变量,考察FDI的环境效应.结果表明,FDI在重、中度污染密集型行业对湖南省的环境产生了显著的负面影响,但是在轻度污染密集型行业产生的是正面影响;总体而言,外资进入湖南省制造行业产生了正面的环境效应.四类污染物排放量与各个行业的工业总产值呈现正向关系,而与企业的研发经费总额呈现反向关系.     

Religious freedom, religious diversity, and Japanese foreign direct investment

Research into the links between religion and foreign direct investment is scarce, partly because research on religion has not been the traditional domain of business and economics. Nevertheless, religion affects the economies, political structures, legal environments, and social behaviors of people around the world and is, therefore, an important element of the international business environments. Foreign direct investment (FDI) decisions are often made after an assessment of the international business environments. This article makes a singular contribution by focusing on the impact of religion – religious freedom and religious diversity – on the foreign direct investment of Japanese companies. We find that national income and religious diversity significantly influence Japanese decisions to invest.