INTERNATIONAL CORPORATE TAX AVOIDANCE: A REVIEW OF THE CHANNELS,MAGNITUDES, AND BLIND SPOTS

This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on the main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral, and corporate inversions. Moreover, it performs a meta-analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1%—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.     

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.     

Managing Discretionary Accruals and Book‐Tax Differences in Anticipation of Tax Rate Increases: Evidence from China

This paper investigates how firms manage their earnings to trade off various incentives when tax rates increase. We hypothesize and find that firms generally choose to manage their taxable income upward in a book‐tax non‐conforming manner rather than in a book‐tax conforming manner before a tax rate increment, which in turn reduces the detection risk of aggressive financial reporting. These results suggest that firms give more weight to tax incentives and tax audit or regulatory inspection risks than to boosting financial reporting income in tax management. However, when firms have higher book management incentives or lower tunneling incentives (i.e., non‐state‐owned enterprises), we find that they manage their taxable income and book income upward together (i.e., in a book‐tax conforming manner), whereas their counterparts (i.e., state‐owned enterprises) do not. Overall, our paper contributes to the literature by demonstrating the interplay of tax, tunneling and financial reporting incentives in influencing tax management strategies. The findings from our paper should also help government and regulators understand more about firms’ reactions to tax rate increases.     

浅析会计利润与应纳税所得额的差异

随着会计准则与税收法规的改革与国际协调,二者之间的关系逐渐倾向于分离模式,因而财务报告披露的会计利润与纳税申报的应纳税所得之间必然存在着与生俱来的差异。本文对这两者主要内容、差异的表现形式及处理方法进行了探讨。     

R&D INTENSITY AND THE EFFECTIVE TAX RATE: A META-REGRESSION ANALYSIS

We apply meta-regression techniques to provide a quantitative review of the empirical literature on how research and development (R&D) expenses affect the effective tax rate (ETR). R&D expenses relate to a well-accepted profit shifting channel, strategic placement of intellectual property within a multinational entity. Using a unique hand-collected data set, we add a new perspective to the current base erosion and profit shifting (BEPS) state of research and debate, in three ways: First, observing that primary studies report mixed evidence on how R&D expenses affect ETR, we provide a consensus estimate for this effect. Second, we consider this effect in more detail by separating a tax accounting effect and a profit shifting effect, which to our knowledge has not yet been investigated. We detect that one-third of the R&D effect on the ETR is due to the tax accounting effect and could be mitigated via book-tax conformity. We further find that 10% of the profit shifting effect can be traced back to R&D tax credits. Third, our meta-regression reveals factors that are possible sources of variation and bias in previous empirical studies.     

The Value Relevance of Foreign Income: an Australian, Canadian, and British Comparison

In this paper we examine the value relevance of geographical earnings disclosures for firms listed and domiciled in Australia, Canada and the United Kingdom. We find that foreign earnings in all three countries are valued differently than domestic earnings. The estimate of the association coefficient for foreign earnings changes with returns is positive in all three countries and statistically larger than the association coefficient for domestic earnings changes in Canada and the United Kingdom. Further tests show that this difference is related to relative growth opportunities of overseas operations to domestic operations. These findings are similar to results for foreign earnings association coefficients for American‐based multinationals found in Bodnar and Weintrop (1997). These results indicate that across countries the market perceives the results of foreign operations as value relevant and suggests that greater emphasis should be placed on the required disclosure of segmental data rather than on the concern that all countries prepare the segmental information using a common GAAP.     

注册在“避税天堂”的公司确实能避税吗？——基于中国海外上市公司的实证研究

近年来,越来越多的中国企业开始在开曼群岛、百慕大群岛等“避税天堂”进行注册,其初衷一方面是降低税务负担,另一方面是利用国际避税地的各种便利条件提升企业盈利能力。这些企业税务负担的经验数据与实证研究,将为我国应对日益激烈的国际税收竞争提供决策依据。因此,利用中国海外上市公司2011年到2015年数据,对企业税负和盈利能力进行了实证研究。结果表明,在国际避税地注册的企业的税负并没有显著低于其他企业税负;在国际避税地注册的企业的盈利能力一般高于其他企业。     

The heterogeneous impact of taxation on economic development: New insights from a panel cointegration approach

In this paper, we study the role of taxation on long-run income performance. In the theoretical part of the study, we develop a stylized model based on Barro (1990), in which income taxation has two contradictory roles in the standard Solow (1956) setup: on the one hand, taxation appropriates resources that would otherwise be used for physical capital accumulation, and on the other, it is the source of government spending, which is used to support private production. In the empirical part of the study, the impact of consumption tax, personal income tax, corporate profit tax and property tax on income is estimated using the common correlated effects (CCE) panel cointegration approach, which allows for cross-sectional dependencies and provides both panel- and country-specific results. The panel findings for 30 OECD countries for the period of 1995–2016 indicate that only consumption tax has a statistically significant negative effect on long-run income. However, because the type and sign of the tax coefficients are heterogeneous for the country-specific results, we conclude that taxation has heterogeneous effects on income.     

Union wage setting and progressive income taxation with heterogeneous labor: theory and evidence from the German income tax reforms 1986–1990

This paper analyzes the effects of tax shifting in a model with union wage setting and progressive income taxation. The setup allows for different skill levels of the workforce and accounts for the union's distributional objective of income equality. The theoretical predictions of the model are empirically tested with a panel of German micro-data covering the period of the income tax reforms 1986–1990. It is shown that average taxes raise wages, whereas increasing the progressivity of the tax system reduces wages. The effect of progressivity on high-skilled labor tends to be less significant and smaller. Stronger preferences for equality compress the (pre-tax) wage distribution.     

Delayed price response to the announcements of earnings and its components in Finland

Several studies report that even after accounting earnings are announced, estimated cumulative unexpected returns continue to drift up for firms that report unexpectedly good earnings and down for firms that report unexpectedly bad earnings. This paper shows that because Finnish companies tend to pay more attention to tax considerations than so-called economic reality when preparing their financial reports, this drift does not exist for reported earnings, i.e. net profit based on Finnish accounting regulations. It appears, however, that several other income levels assessed by financial statement analysis are important in this respect. The results imply that firms that make extensive adjustments for tax purposes have high unexpected returns. This is explained by the fact that those firms have enough income to extensively exploit the depreciation and other earnings management possibilities.     

Do Corporate Tax Concessions Really Matter for the Success of Free Economic Zones?

Not only a large number of developing countries but also transition economies have established free economic zones (FEZs) with the aim of attracting foreign capital by providing tax incentives, creating employment opportunities, and promoting exports and regional development. Tax investment promotion schemes include profit tax exemption, free or accelerated depreciation, investment tax allowance, subsidy for investment costs, etc., the effects of which on firms investment decisions can be compared based on the net present value model. This study suggests that even a low corporate tax rate combined with generous depreciation rules does not provide incentives for investors when the inflation rate is high. A case study on Najin–Sonbong FEZ in North Korea delivers a wide range of more crucial economic and political reasons why such a development project can fail, although tax concessions offered there are more favourable than those in China and other Asian nations.     

盈余管理、审计费用与所得税会计政策选择——基于沪深A股上市公司年报数据的实证分析

本文以2003～2005年沪深A股上市公司年报数据为依据,分析了所得税会计核算方法选择与盈余管理程度、审计费用水平之间的关系。研究发现:在我国现行的应税收益-会计收益的差异水平下,应付税款法与纳税影响会计法核算的总体绩效评价指标、盈利预测误差程度均没有显著差异;而采用纳税影响会计法的公司,其盈余管理程度、审计费用水平(“簿记成本“的替代变量)均显著高于采用应付税款法的公司,说明盈余管理与薄记成本是影响所得税会计政策选择的重要因素。     

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.     

浅议我国现行个人所得税制改革

个人所得税作为调节居民收入分配的一个重要税种,在我国经济生活中起着至关重要的作用。个税调整直接关系百姓钱袋子,在通胀形势下成为关注热点。随着我国经济的增长,居民可支配收入也在逐年增多,但是作为调节贫富收入差距的"个人所得税"这一税收杠杆却滞后于我们经济的变化,这些问题不仅严重影响了税收调节经济的功能,而且对社会稳定也极为不利。本文在阐明了我国个人所得税制改革中存在的相关问题后,有针对性的提出了相关学者的政策建议。     

Why is there so little tax coordination? The role of majority voting and international tax evasion

It is a striking feature of EU tax policy that countries find it difficult to agree on capital tax coordination. This is in conflict with the prevailing theoretical view, according to which tax coordination is beneficial. This paper develops a political economy argument which may help to explain this puzzle. We consider a model of tax competition where fiscal policy decisions are taken via majority voting and tax evasion is possible but costly. It turns out that tax coordination agreements may fail to generate political support because middle income groups may lose from tax coordination, even if their capital income is below average.     

TAX COMPETITION AS A CAUSE OF FALLING CORPORATE INCOME TAX RATES: A SURVEY OF EMPIRICAL LITERATURE

Abstract Since the mid 1980s, tax rates on corporate income have declined in most industrialized countries. Tax competition between countries for mobile capital has frequently been mentioned as an explanation for this development. A vast empirical literature dealing with tax competition for mobile capital has emerged. This paper categorizes and summarizes the existing empirical studies on this issue. Particular focus is placed on the isolation of the substantive implications the quantitative study outcomes convey. Given the empirical evidence surveyed, it appears that tax rates indeed decline due to tax competition between countries, and in particular due to competition for profits. In addition to summarizing the substantive implications of the existing empirical literature, the paper addresses the question of whether the existing studies can convincingly isolate tax competition as a driver of falling corporate income tax rates.     

EFFECT OF CROSS‐BORDER HEALTH CARE ON QUALITY AND PROGRESSIVITY OF FINANCING

In this study, we examine the effect of cross‐border health care in terms of public health insurance. We consider its effect on healthcare quality and progressivity of financing. We use a two‐country Hotelling model in which consumers are divided into two groups: high and low innate‐talent consumers. Aiming to maximize social welfare, governments impose a progressive income tax on consumers to provide healthcare services. Assuming that a payment scheme for healthcare services is based on diagnosis‐related group pricing, which has been adapted in many countries, we obtain the following results. The promotion of cross‐border health care does not influence healthcare quality or the progressivity of financing in patient‐importing countries, but does reduce healthcare quality and influence the progressivity of financing in patient‐exporting countries.     

HARMFUL TAX COMPETITION?

European governments are currently engaged in an assault on tax havens, to stamp out what they call 'unfair tax competition.' This article examines and rejects the arguments they use to justify this action and shows that tax competition is (like all forms of competition) beneficial, except perhaps as practised by European governments themselves.     

Does Tax Evasion Affect Occupational Choice?*

This paper presents a novel micro‐econometric procedure that identifies the extent to which occupational choices are distorted by opportunities for tax evasion. Previous studies claim to have found significant and substantial effects, but analysis and replication of their methods reveals that they generate conflicting and misleading results. The paper then implements the new procedure using several British micro‐data sets. A thorough empirical investigation reveals that occupational choice between self‐employment and paid employment is not robustly related to pecuniary factors in general, and is invariant to tax avoidance and evasion opportunities in particular.     

Tax enforcement policies,tax evasion and time allocation

Several studies examine the effect of tax rates on households’ labor supply decisions in attempts to account for observed differences in work hours across countries. Interestingly, these studies fail to consider a fundamental action associated with taxation: tax evasion. This paper introduces, into a general equilibrium model of household labor supply, the possibility that households can evade labor income taxes. We show that the relationship between tax-enforcement policies, the elasticity of substitution between consumption and leisure and the elasticity of substitution between formal and informal work is key to explain formal labor supply in major OECD countries. In a model without informal work, there is a positive relationship between the elasticity of substitution and the tax rate on formal income and people tend to work more. This is the case for the United States, Greece, Finland and the United Kingdom. This relationship becomes negative once informal activities are introduced and the model can explain formal labor supply better in countries where agents work relative less, i.e., in Austria, Denmark, France, Germany, Spain, Norway and Sweden. We also obtain estimates of hours worked in the informal sector for these countries.