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Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513568558
Category : Business & Economics
Languages : en
Pages : 17
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Book Description
Thin capitalization rules (TCRs) aim to mitigate profit shifting by multinational corporations (MNCs) but, by raising the cost of capital for affected affiliates, can also negatively affect real investment. Exploiting unique panel data on multinational companies in 34 countries during 2006-2014, we estimate that the size of this adverse investment effect can be large, and dependent on the statutory corporate tax rate and the tightness of the safe-haven ratio. Negative investment effects are more pronounced for highly-levered firms for which TCRs are more likely to be binding.
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1513568558
Category : Business & Economics
Languages : en
Pages : 17
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Book Description
Thin capitalization rules (TCRs) aim to mitigate profit shifting by multinational corporations (MNCs) but, by raising the cost of capital for affected affiliates, can also negatively affect real investment. Exploiting unique panel data on multinational companies in 34 countries during 2006-2014, we estimate that the size of this adverse investment effect can be large, and dependent on the statutory corporate tax rate and the tightness of the safe-haven ratio. Negative investment effects are more pronounced for highly-levered firms for which TCRs are more likely to be binding.
Author: Martin Eckhoff Andresen
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
Escape clauses, where small firms are exempt from particular tax rules, is a crucial feature of a number of corporate tax schemes, but creates incentives to avoid taxation by manipulating the measures that determine inclusion. We evaluate the impact of thin capitalization rules, which commonly feature such escape clauses across the world, by exploiting the introduction of these rules in Norway in 2014. Combining difference-in-differences, regression discontinuity and bunching estimates, we show that what appears to be a strong response in the capital structure among exposed firms primarily reflect within-group reallocation of debt to avoid exposure to the rules. We observe sharp bunching among both new and existing subsidiaries at both thresholds for rule inclusion, and find that internal corporate group debt is offloaded to these bunching subsidiaries in order to avoid additional tax costs. As a result, significant and large effects on firm-level capital structure in response to the thin capitalization rules is driven by reshuffling of capital within corporate groups with little real effects. Re-estimating the difference-in-difference specification at the corporate group level confirms this finding, questioning the extent to which thin capitalization rules affect the real economy due to the presence of escape clauses.
Author: Mohammed Mardan
Publisher:
ISBN:
Category :
Languages : en
Pages : 33
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Book Description
In the absence of financial frictions, the purpose of thin capitalization rules is to limit multinational firms' possibilities of engaging in tax planning via debt shifting. This paper analyzes the effects of thin capitalization rules in the case where firms have limited access to external funding. First, we show that a host country allows positive internal interest deductions if its financial development is sufficiently low. This amount increases when the financial development of the host country worsens. Then we ask which of the two most common thin capitalization rules used in practice is better suited to maximizing welfare of the host country. We show that welfare under a safe haven rule is higher than under an earnings stripping rule if firms are not able to manipulate transfer prices. Welfare, however, can be higher under an earnings stripping rule if firms are able to manipulate transfer prices. The analysis provides an explanation for why countries differ in the strictness and in the type of thin capitalization rule.
Author: Ruud A. de Mooij
Publisher: International Monetary Fund
ISBN: 1475578296
Category : Business & Economics
Languages : en
Pages : 20
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Book Description
Tax provisions favoring corporate debt over equity finance (“debt bias”) are widely recognized as a risk to financial stability. This paper explores whether and how thin-capitalization rules, which restrict interest deductibility beyond a certain amount, affect corporate debt ratios and mitigate financial stability risk. We find that rules targeted at related party borrowing (the majority of today’s rules) have no significant impact on debt bias—which relates to third-party borrowing. Also, these rules have no effect on broader indicators of firm financial distress. Rules applying to all debt, in contrast, turn out to be effective: the presence of such a rule reduces the debt-asset ratio in an average company by 5 percentage points; and they reduce the probability for a firm to be in financial distress by 5 percent. Debt ratios are found to be more responsive to thin capitalization rules in industries characterized by a high share of tangible assets.
Author: Mr. Luc Laeven
Publisher: International Monetary Fund
ISBN: 1451910568
Category : Business & Economics
Languages : en
Pages : 40
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Book Description
This paper presents a model of a multinational firm''s optimal debt policy that incorporates international taxation factors. The model yields the prediction that a multinational firm''s indebtedness in a country depends on a weighted average of national tax rates and differences between national and foreign tax rates. These differences matter because multinationals have an incentive to shift debt to high-tax countries. The predictions of the model are tested using a novel firm-level dataset for European multinationals and their subsidiaries, combined with newly collected data on the international tax treatment of dividend and interest streams. Our empirical results show that corporate debt policy indeed not only reflects domestic corporate tax rates but also differences in international tax systems. These findings contribute to our understanding of how corporate debt policy is set in an international context.
Author: Omolara Okesola
Publisher:
ISBN:
Category :
Languages : en
Pages : 20
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Book Description
Dwindling oil revenue in Nigeria has necessitated the need to generate more government revenue through other sources. A potential area to generate more government revenue is through taxes on corporate profits. However, the prospects of generating more tax revenues have been perceived internationally to be weakened by aggressive corporate tax planning amongst multinational companies especially through internal debt shifting from jurisdictions with lower tax rates to jurisdictions with higher tax rates for the overall reduction in group tax liabilities. The capital structure of an organization determines the level of interest expense deductions from taxable income. That is, a highly leveraged company would be able to deduct more interest expenses on debt compared to a lower leveraged company. As a result of this tax loophole explored by multinational companies, most countries have introduced thin capitalization rules to reduce base erosion and profit shifting. Currently, Nigeria has no thin capitalization rules in effect, there are many benefits from thin capitalization rules from regulatory perspective. This paper seeks to examine the effects of thin capitalization rules on tax revenue by using the Latvian economy as a case study. Latvia is an emerging economy and it is has implemented thin capitalization since 2003. Data on taxes on corporate profits, gross fixed capital formation annual percentage growth, short- term interest rates on loan in the Euro Area (EA) and adjusted net national income percentage growth for the period of 2000 to 2016 were obtained from the Organization for Economic Co- operation and Development (OECD) and the World Bank database. This paper applied the multiple regression model. The results show that the dummy variable for thin capitalization policy is statistically insignificant to tax revenue in Latvia, however short-term interest rate on loans in the EA has a significant impact on tax revenue in Latvia.
Author: Shafik Hebous
Publisher: International Monetary Fund
ISBN: 1484381904
Category : Business & Economics
Languages : en
Pages : 26
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Book Description
Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.
Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 148436399X
Category : Business & Economics
Languages : en
Pages : 45
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Book Description
This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on 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 percent—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.
Author: International Monetary Fund. Fiscal Affairs Dept.
Publisher: International Monetary Fund
ISBN: 1498345204
Category : Business & Economics
Languages : en
Pages : 78
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Book Description
Risks to macroeconomic stability posed by excessive private leverage are significantly amplified by tax distortions. ‘Debt bias’ (tax provisions favoring finance by debt rather than equity) has increased leverage in both the household and corporate sectors, and is now widely recognized as a significant macroeconomic concern. This paper presents new evidence of the extent of debt bias, including estimates for banks and non-bank financial institutions both before and after the global financial crisis. It presents policy options to alleviate debt bias, and assesses their effectiveness. The paper finds that thin capitalization rules restricting interest deductibility have only partially been able to address debt bias, but that an allowance for corporate equity has generally proved effective. The paper concludes that debt bias should feature prominently in countries’ tax reform plans in the coming years.
Author: Valeria Merlo
Publisher:
ISBN:
Category :
Languages : en
Pages : 37
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Book Description
This paper examines how restrictions on the tax-deductibility of interest cost affect location choices of multinational corporations (MNCs). Many countries have introduced so-called thin-capitalization rules (TCRs) to prevent MNCs from shifting tax base to countries with lower tax rates. As of 2012, in our sample of 172 countries, 61 countries have implemented a TCR. Using information on nearly all new foreign investments of German MNCs, we provide a number of new and interesting insights in how TCRs affect the decision of where to locate foreign entities. These results include estimates of own- and cross-elasticities of location choice and also novel results on the relative importance of tax base vs. tax rate effects. We finally provide estimates for different uncoordinated as well as coordinated policy scenarios.