The Effect of Cross-Border Group Taxation on Ownership Chains

ABSTRACT

This study investigates the influence of taxation on ownership chains and specifically on the location decision for intermediate holding companies. By examining the effect of the introduction of a cross-border group taxation regime in Austria in 2005 on ownership chains of European multinational firms, I find evidence that foreign parent companies already invested in Austria restructured their ownership chains in order to meet the requirements of the group taxation regime. This effect is larger for foreign parent companies with loss-generating subsidiaries. Collectively, the empirical findings suggest that, when evaluating the effect of cross-border group taxation regimes, companies follow a detailed tax planning strategy that takes tax-base effects into account.     

我国证券市场中的所得税问题研究

欧美和日本等国家的上市公司偏好于债务融资,而我国的上市公司在进行融资决策时普遍采用"轻债务重股权"的方法。本文认为这主要是因为我国的所得税制中存在对股权收益的部分征税、重复征税,对证券的投资收益和转让利得实行差别税收政策,以及存在非债务税收保护措施等,所以必须有针对性地改革现行税制,对股息所得征税遵循"同股同利"的原则,清理不恰当的非债务税收保护措施,减轻对股利的重复课税以及改革证券市场的资本利得税。     

Is corporate payout taxation a long run phenomenon? Evidence from international data

This paper examines whether dividend and capital gains taxation influences corporate payout policy using the country level data of 21 countries in panel versions of time series models. We find that dividend relative to capital gains tax penalty is cointegrated with corporate payouts (dividends and share repurchases) i.e. corporate payout taxation may be a long run phenomenon. Further, the cointegrating vector estimates are largely consistent with the traditional view of dividend taxation whereby the tax penalty discourages dividends, while the estimates give limited support to the premise that firms substitute dividends for share repurchases in response to an increase in dividend tax penalty. Long run causality also operates between the tax penalty and payouts in the error correction models. Additionally, dividend tax appears to be more influential than capital gains tax on dividend payout decisions. Lastly, taxation affects dividends more significantly in countries with high investor protection.     

Does having a semimandatory dividend policy enhance investor confidence? Research on dividend-financing behavior

Enhancing investor confidence is crucial for sustainable and stable development of the capital market. Does having a semimandatory policy to pay dividends help to enhance investor confidence? What is the origin of the cash dividend paid by companies to meet regulatory requirements so as to enhance investor confidence? Based on these considerations, this paper uses the exogenous policy shock that in 2006 the China Securities Regulatory Commission required listed companies to pay accumulated dividends of no less than 20 % of average annual distributable profits and adopts a panel difference-in-difference estimation strategy to explore whether this new policy has significantly enhanced investor confidence. In addition, it explores the source of external financing for cash dividends by examining dividend-financing behavior. The results show that the semimandatory dividend policy has led to new dividend-financing behavior by listed companies. The cash dividend paid by companies comes mainly from external financing, especially a net increase in debt. The paper expands the traditional theory of dividend payment and provides a reference point for decision-making by shareholders, company managers, and regulatory agencies.     

我国个人所得税改革的误区及其突破

我国个人所得税改革存在一定的误区:税制改革的重点在于流转税、当前个税属于综合与分类相结合的税收模式、劳动所得作为个税的改革核心等。反思改革误区,我国个人所得税改革应实现三点突破:一是个税改革重点应由劳动所得转向资本所得,以股息和红利所得作为资本所得课税的改革核心,取消根据持有时间长短而差别计税的优惠政策;二是不断扩大个人所得综合征税的范围,逐步实现对资本所得的综合课税、以半二元模式作为我国综合与分类相结合的个税改革模式;三是缓步实现对个人所得税的"增税"调整,促进我国税制结构向"双主体"模式合理过渡。     

Housing, taxation and retirement provision

This paper considers the tax treatment of housing and the issue of savings for retirement in the context of a simplified model that still allows key aspects of the household context to be realistically represented. A model is developed in which both housing and financial assets can be used as vehicles for household saving. Individuals face perfect capital markets and choose between owner-occupied and rented accommodations. For the model developed, it is shown that the tax advantage of owner-occupied housing is not fully removed even if imputed rents are subject to income taxation. However, deferred income taxation for both housing and savings in the form of financial assets would result in an equal treatment of tenants and owner-occupiers.     

Agency costs and dividend payments: The case of bank holding companies

This paper examines the hypothesis that agency costs are a primary factor motivating dividend payments. Norohna et al. (1996) present evidence that the agency cost rationale is context specific and that dividends will not be driven by agency costs when other mechanisms exist for controlling agency problems. We argue that regulation of bank holding companies involves a context specific case where agency costs may be less relevant. Using an empirical methodology similar to Born and Rimbey’s (1993), we find that the abnormal returns associated with dividend announcements by bank holding companies are not related to their external financing activities. The monitoring activities of the capital markets are not a rationale for dividend payments in the presence of bank regulation. Our results are robust to an alternative explanation involving the signaling role of new equity financings.     

投资者情绪、股利政策与公司价值研究

基于行为金融学背景对股利政策的信号传递作用进行的研究发现,在不同的投资者情绪条件下,股利政策信号传递的效应存在差异。在股市上涨时期,不同股利政策对投资者的投资决策的影响几乎没有显著差异;在股市下跌时期,现金股利成为投资者获得收益的主要来源,因此发放现金股利的公司受到市场追捧。因此,上市公司股利政策制定不仅要考虑自身情况,还需要考虑市场情绪。     

Intertemporal Commitment Problems and Voting on Redistributive Taxation

A rich person who fears a loss of income may later favor redistributive taxation and a mix of taxes and public goods that differs from the one he now favors. If mobility is costly, and if government in each period uses majority voting to determine policy, then this person may prefer to live in a community that is permanently ruled by poor residents. Majority voting is a mechanism that can overcome intertemporal commitment problems of income insurance.     

Trading income and bank charter value during the financial crisis: Does derivatives dealer designation matter?

Derivative markets have exploded over the last decade, remained active in the midst of the 2007–2009 financial crisis and continue to be dominated by a small group of bank holding companies (BHC). BHC motives for derivative usage are usually tied to hedging purposes (balance sheet risk management), trading purposes (profit motives) or some combination thereof. This paper examines the relationship between derivative trading income and bank charter value for 27 BHC between 2001Q1 and 2011Q3. We find that the impact of derivative trading income on bank charter value, using Tobin's Q, is very small and seems to be tied to BHCs derivatives dealer trading designation. We also find that trading incomes are a modest fraction of net operating revenue, highly volatile, and did not contribute to overall BHC income during the crisis.     

巧算所得税中的递延所得税资产(负债)

文章介绍一种计算递延所得税资产的简便算法,从演变所得税的计算公式入手,通过分析递延所得税资产(负债)对本期和未来所得税影响的关系,推算所得税中递延所得税资产和递延所得税负债。     

再融资公司的现金分红和现金流操控研究

证监会2006年和2008年相继发布了强制拟再融资上市公司分派现金股利的文件,旨在提高股东回报。以2006年和2007年A股再融资上市公司为样本,对这些政策颁布前后上市公司分红和现金流的变化情况进行研究发现,在证监会强制要求下,上市公司的分红水平有所提高,但股利分派也成为了大股东转移公司利益的手段。而且,公司的现金流在再融资前后波动较大,存在被操控的迹象。     

农地股份合作组织盈余分配机制的利益衡量

当前我国农地股份合作组织的盈余分配机制主要有盈利分红、收益不保底,收益保底、盈利不分红和既收益保底、又盈利分红三种形式。各地股份合作组织对于盈余分配机制的选择,一般都会受到农民收入和农地股份合作组织盈余两个利益因素的影响。本文以庞德的利益衡量理论对这两种利益进行了分析,认为现阶段我国农地股份合作组织采用既收益保底、又盈利分红的盈余分配机制是适当的,并提出了完善的建议。     

上市公司超能力派现信号效应实证研究

上市公司超能力派现已引起了广泛的关注,然而这一现象可能导致的市场反应却不为人们所了解。作者以深、沪两市2005年实行超能力派现上市公司为研究对象,根据股利公告日前后股价的变动资料,采取累计超额收益率进行实证研究,以此来分析市场对超能力派现的反应。实证研究结果表明,超能力派现对公司的股价具有负的信号传递作用。     

The 1986 Tax Reform Act and ex-dividend day price and volume patterns: Evidence from organized exchanges and the OTC market

By effectively removing the differential taxation of dividends and capital gains, the 1986 Tax Reform Act provides a unique opportunity to re-examine the “tax induced clientele” explanation of ex-dividend day price behavior. The analysis indicates an increased preference for dividends and provides evidence of significant abnormal volume during the ex-dividend period, consistent with dividend induced trading activity. In addition, the level of dividend preference is found to be far greater on the organized exchanges than in OTC trading.     

上市公司“超能力派现”影响因素的实证研究

本文首先对“超能力派现”进行了界定,然后以2000年￣2003年“超能力派现”的公司作为总体样本,采用Logistic模型分析了我国上市公司“超能力派现”的影响因素,研究结果表明,第一大股东性质、公司上市年限、大股东中投资基金个数、资产负债率、上市公司净资产收益率是否接近配股达标线区间(6%￣7%),均对“超能力派现”有显著影响。     

A discrete choice model of dividend reinvestment plans: classification and prediction

We use a discrete choice recursive model to classify companies with and without dividend reinvestment plans (DRIPs). Our model classifies 72.0% of companies correctly. We interpret misclassified companies as being likely to switch their plan status. For example, if financial data erroneously suggest that a company should have a DRIP then we expect that it would be more likely to institute a plan than other companies in the sample. Our results support this conjecture. Companies that add DRIPs tend to have more extreme levels of variables that control for management entrenchment, higher levels of variables that control for the ability to pay dividends and higher payout ratios. Copyright © 2011 John Wiley & Sons, Ltd.     

Hard Times or Great Expectations? Dividend Omissions and Dividend Cuts by UK Firms*

This paper uncovers an increasing proportion of quoted UK companies omitting cash dividends. Using a large panel of quoted UK firms, we estimate panel data probit models for the incidence of dividend omissions and cuts as functions of financial characteristics including cash flow, leverage, investment opportunities, investment and company size. These variables account for most of the increase in omission since 1995. There is relatively little evidence to link this to the major tax reform of 1997 that abolished tax refunds on dividend income payable to tax‐exempt institutions. Significant persistence effects indicate companies are slow to adjust their balance sheets through their dividend.     

Financial Pressure and Balance Sheet Adjustment by Firms*

This paper examines the financial policies and balance sheet adjustment of companies. Using a large panel of UK‐listed firms we consider how companies resolve pressures on their balance sheet, estimating models for dividends, new equity issuance and investment. The results indicate that companies resolve balance sheet pressures by each of these means. Financial policies, through dividends and new equity issuance, and real investment decisions, respond to the underlying level of debt and the borrowing cost of servicing that debt. Dividends are estimated to be slow to adjust in the short run.     

Taxation and income shifting: Empirical evidence from a quasi-experiment in China

China's new Corporate Income Tax Law was passed in March 2007 and took effect on January 1, 2008. It terminated the dual corporate income tax regime by removing the preferential tax treatments offered to foreign investment enterprises (FIEs) and unifying the corporate income tax regime for FIEs and Chinese domestic enterprises (DEs). This article uses a difference-in-differences approach to determine whether FIEs responded to the law by shifting income out of China. Employing the Chinese Industrial Enterprises Database from 2002 to 2008 to implement the analysis, we find that FIEs have responded to the law by shifting income out of China; the treatment effect for Hong Kong-Macau-Taiwan (HMT) investment enterprises is less negative than that for other FIEs, which implies that HMT investment enterprises might be less capable of shifting income across countries than other FIEs. The treatment effect by restricting the control group to State-Owned Enterprises (SOEs) is less negative than that by restricting the control group to Private-Owned Enterprises (POEs), which is consistent with the perception that SOEs might enjoy more favorable treatment from the Chinese government than POEs. All three findings are consistent with tax-induced income shifting, and hence we conclude that taxation plays an important role in income shifting activities.