Corporate tax reforms and tax-motivated profit shifting: evidence from the EU

This paper examines whether the profit-shifting trend in Europe during 2003–2013 can be explained by tax policy changes. Consistent with prior literature, we find that affiliates’ profits are sensitive to tax rate changes. However, we document that tax base–broadening reforms have mitigated the incentives for both inward and outward profit shifting. In particular, we find that anti-avoidance rules prevent multinational companies from shifting profits out of their foreign affiliates, whereas other tax base–broadening rules, such as restrictions on the deductibility of tax losses or on group tax relief, reduce the incentives for multinational companies to shift profits into foreign affiliates. Furthermore, we find evidence of a downward trend in profit shifting across European countries, especially when the tax enforcement is stricter. Overall, these results suggest that broader tax bases and stricter tax enforcement have successfully curbed this particular tax strategy.     

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。     

Explaining the competition for FDI: Evidence from Costa Rica and cross-national industry-level FDI data

Attracting foreign direct investment (FDI) has become an integral part of the economic development goals of policymakers throughout the world. Previous literature on FDI attractiveness has identified a host of factors that make a country more or less enticing for FDI. Where the literature is less developed is in explaining what occurs when multiple countries are roughly equal across those factors. In this paper, we argue that when several potential host countries (HCs) are on par in attractiveness, a competition arises between them, such that the HC willing to offer the most concessions to the potential foreign investor attracts the investment. We further argue that this competitive relationship holds in some industrial sectors, but not in others, with the difference centered on location constraints. Using both a case study of Costa Rica’s investment promotion activities and cross-national industry-level FDI analyses, we find evidence that concessions are greater in the manufacturing sector, where countries are often equally attractive to FDI, but lower in mining, where natural resource endowments determine FDI attractiveness.     

International Corporate Tax Avoidance Practices: Evidence from Australian Firms

This paper examines the international corporate tax avoidance practices 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 there are several practices Australian firms use to aggressively reduce their tax liabilities. Specifically, we find that thin capitalization, transfer pricing, income shifting, multinationality, and tax haven utilization are significantly associated with tax avoidance. In fact, based on the magnitude and significance levels of the regression coefficients in our study, thin capitalization and transfer pricing represent the primary drivers of tax avoidance, whereas income shifting and tax haven utilization are less important. Finally, our additional regression results show that tax havens are likely to be used together with thin capitalization and transfer pricing to maximize international tax avoidance opportunities via the increased complexity of transactions carried out through tax havens.     

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.     

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.     

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.     

外资房地产企业存在的税收问题及对策建议

近年来,我国外资房地产行业发展迅猛,加强对其的税收征管与检查尤显重要。本文从所得税稽查的角度出发,对外资房地产企业存在的主要问题和相应的检查思路进行了剖析点评,并就日常征管中如何掌握基础数据、进行实地检查、保证及时结算、加强发票管理和完善政策规定等提出了建议。     

从国际经济学理论视角看企业竞争优势——兼议国际经济学优势思想的演进

本文通过回顾和分析国际经济学中国际贸易理论和国际直接投资理论优势思想的发展和]进,说明了理论研究可以通过对各种市场结构的细分,把优势分析引入到企业内部,并通过对分工、市场结构与交易费用之间的矛盾关系的深入研究,探讨内生优势与外生优势之间的对立统一关系,而企业竞争优势的培育则是一个建立在企业自身独特能力基础上的、综合利用企业内外部各种比较优势的动态累积发展过程。     

Predictors of revenue shifting and expense shifting: Evidence from an emerging economy

Prior literature established that managers engage in Revenue Shifting (RS) and Expense Shifting (ES) with an intent to report favourable operating performance; our paper extends such research in a new direction by investigating both forms based on the need, ease, and advantage of each form of shifting strategy. The study identifies firm-specific factors that incentivize firms to prefer RS over ES and vice-versa. We undertake a longitudinal study (2001–2019) using a sample size of 39,634 firm-years, enlisted in the Bombay Stock Exchange (BSE). Our results show that peer-performance, size, financial leverage, growth opportunities, accounting flexibility, and age of the firm are important determinants of RS and ES. Specifically, our results exhibit that large, levered, old, and high-growth firms are engaged in RS, whereas small, young, firms with lesser accounting flexibility, and firms operating below peer-performance are involved in ES. These results are robust to controlling for accruals earnings management, real earnings management, endogeneity, self-selection bias, and alternative measures of RS and ES. Our findings are helpful to auditors and investors in improving awareness of forms of classification shifting.     

The impact of tax holidays on earnings management: An empirical study of corporate reporting behavior in a developing-economy framework

This study investigates whether foreign investment enterprises (FIEs) in China alter their corporate reporting behavior in response to a known schedule of tax-rate increases. The context of this investigation is a tax-incentive scheme that allows firms to pay taxes at a reduced rate for a limited period of time, and then at a higher rate when this period expires. If managers attempt to maximize firm value by minimizing tax costs, then the spread of tax rates in the periods surrounding the rate change may provide a substantial incentive for them to accelerate revenue and defer expenses. Consistent with this hypothesis, the empirical results indicate that firms report significantly higher discretionary current accruals for the years before tax-rate increases. The evidence, which indicates that firms manage earnings upward to take advantage of lower tax rates that are available in certain years, has important implications for tax policymakers.     

嵌入性与税收政策对外资投资决策的影响

引进外资是我国对外开放的重要组成部分。本文认为"区域(或产业)嵌入性"与"税收政策"是影响外资投资决策的两个主要因素,应该在研究通过税收政策吸引与稳定外资的同时,考虑如何先通过税收政策来加强产业集群的嵌入性,从而更有效地吸引和利用外资。     

Regional favoritism and tax avoidance: evidence from China

This paper investigates the effect of officials’ regional favoritism on corporate tax avoidance activity in China. We find that firms located in regions that were formerly administered by the current provincial governors have a higher level of tax avoidance than other firms in the province. Further evidence indicates that regional favoritism affects tax avoidance through two channels: regional politicians’ personal connections with the governor and firms’ political access to the governor. Overall, the findings support China's current official selection and promotion guidelines that restrict hometown favoritism. Our results further imply that favoritism can also extend to officials’ former administrative regions.     

Tax risk management and the multinational enterprise

The financial scandals in the United States and other countries ushered in financial reporting and corporate governance reforms that extend beyond the U.S. Sarbanes-Oxley Act of 2002 (SOX). These initiatives have increased the international financial community's awareness of the importance of risk management and internal controls. Tax risk management and related internal controls have been accorded less focus than risk management generally. The purpose of this research is to describe the current state of tax risk management of multinational enterprises (MNEs) by reporting survey responses from chief financial officers (CFOs) of U.S. and non-U.S. MNEs. The research shows that significant progress has been made by large MNEs in developing and implementing both general and tax risk management policies. The results provide guidance in identifying the loci and impact of organizational tax risk and indicate that respondents do not perceive alarming degrees of tax risk in their organizations. The study reveals a remarkable degree of similarity in U.S. and foreign firm responses and demonstrates, unexpectedly, that existing reporting structures enable CFOs to shift a significant degree of tax risk management to heads of tax.     

电子商务环境下的外资企业避税与反避税

外资企业的避税与反避税是一个长期而又普遍的问题,电子商务的出现和迅速发展使这一问题变得日益复杂,从而带来新的挑战。本文分析了电子商务环境下外资企业避税的新动向,并提出了完善税收法律法规、制定严格的税务登记和管理制度、建立涉外税收信息库等反避税政策建议。     

Bilateral investment treaties and foreign direct investment: Evidence from emerging market firms

Bilateral investment treaties (BITs) help developing countries attract foreign direct investment (FDI) from developed countries. However, whether BITs matter for emerging market firms’ (EMFs) FDI is unclear. This paper investigates how BITs affect EMFs’ FDI locations using conditional logit models with firm-level panel data from 2003 to 2015. The results show that BITs can help host countries attract FDI from emerging market countries. BITs work alongside good institutions to increase the attractiveness of FDI, irrespective of a host country being developed or not.     

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.     

借鉴欧盟经验 处理好中国与东盟税收关系

本文介绍了欧盟成员国通过税收协调推进区域税收一体化的进程,在此基础上,提出推动中国与东盟各成员国间税收协调的政策建议,以营造中国—东盟自由贸易区稳步发展的税收环境。     

Tax avoidance in family firms: Evidence from large private firms

Ownership structure plays an important role in firms’ decisions on tax avoidance. Recently, the effect of family ownership on corporate tax avoidance has become an issue of increasing interest among scholars from both the fields of family business research and tax research; however, empirical findings have so far remained ambiguous. Based on a unique sample of 678 large private firms from Germany, we show that for unlisted large firms (i) family firms avoid more tax than non-family firms, (ii) tax avoidance increases with the percentage of family ownership, and (iii) tax avoidance is a function of the number of shareholders. We interpret our results as evidence that benefits from avoiding taxes outweigh the non-tax costs in the case of large private family firms in Germany. Furthermore, as the number of family shareholders increases, family firms satisfy increasing demand for dividends by avoiding taxes.