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What determines the use of holding companies and ownership chains?

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Author Info
Alfons J. Weichenrieder () (Johann Wolfgang Goethe Universität, Frankfurt & CESifo)
Jack Mintz (Rotman School of Management, University of Toronto)

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Abstract

The paper investigates the role of holding companies and conduit entities in German inbound and outbound FDI. It identifies the relevant conduit countries that act as stepping stones. Several tax and non-tax factors for the set-up of indirect structures are empirically identified. Withholding taxes, credit systems in capital exporting countries and the possibility of group consolidation are shown to be empirically important for the design of ownership chains in foreign direct investment.

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Publisher Info
Paper provided by Oxford University Centre for Business Taxation in its series Working Papers with number 0803.

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Date of creation: 2008
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Handle: RePEc:btx:wpaper:0803

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Related research
Keywords: Holding company; FDI; taxation; treaty shopping;

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Find related papers by JEL classification:
H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

This paper has been announced in the following NEP Reports:

References listed on IDEAS
Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
  1. Jack M. Mintz, 2003. "Conduit Entities: Implications of Indirect Tax-Efficient Financing Structures for Real Investment," International Tax Program Papers 0410, International Tax Program, Institute for International Business, Joseph L. Rotman School of Management, University of Toronto, revised Sep 2004. [Downloadable!]
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  2. Jack Mintz & Alfons Weichenrieder, 2005. "Taxation and the Financial Structure of German Outbound FDI," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich. [Downloadable!]
  3. Weichenrieder, Alfons J., 1998. "Foreign profits and domestic investment," Journal of Public Economics, Elsevier, vol. 69(3), pages 451-463, September. [Downloadable!] (restricted)
  4. James R. Hines Jr., 1994. "Credit and Deferral as International Investment Incentives," NBER Working Papers 4191, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  5. Ramb, Fred & Weichenrieder, Alfons J, 2005. "Taxes and the financial structure of German inward FDI," Discussion Paper Series 1: Economic Studies 2005,05, Deutsche Bundesbank, Research Centre. [Downloadable!]
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  6. Leechor, Chad & Mintz, Jack, 1993. "On the taxation of multinational corporate investment when the deferral method is used by the capital exporting country," Journal of Public Economics, Elsevier, vol. 51(1), pages 75-96, May. [Downloadable!] (restricted)
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Cited by:
(explanations, Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.)

  1. Marcel Gérard, 2006. "Reforming the Taxation of Multijurisdictional Enterprises in Europe, a Tentative Appraisal," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich. [Downloadable!]
  2. Claudia M. Buch & Jörn Kleinert, 2006. "Who Goes East? The Impact of Enlargement on the Patterns of German FDI," IAW Discussion Papers 24, Institut für Angewandte Wirtschaftsforschung (IAW). [Downloadable!]
  3. Schindler, Dirk & Schjelderup, Guttorm, 2008. "Multinationals, Minority Ownership and Tax-Efficient Financing Structures," Discussion Papers 2008/19, Department of Finance and Management Science, Norwegian School of Economics and Business Administration. [Downloadable!]
  4. Fuest, Clemens & Hemmelgarn, Thomas & Ramb, Fred, 2006. "How would formula apportionment in the EU affect the distribution and the size of the corporate tax base? An analysis based on German multinationals," Discussion Paper Series 1: Economic Studies 2006,20, Deutsche Bundesbank, Research Centre. [Downloadable!]
  5. Alfons Weichenrieder & Helen Windischbauer, 2008. "Thin-Capitalization Rules and Company Responses Experience from German Legislation," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich. [Downloadable!]
  6. Thiess Buettner & Nadine Riedel & Marco Runkel, 2008. "Strategic Consolidation under Formula Apportionment," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich. [Downloadable!]
    Other versions:
  7. Clemens Fuest & Thomas Hemmelgarn & Fred Ramb, 2007. "How would the introduction of an EU-wide formula apportionment affect the distribution and size of the corporate tax base? An analysis based on German multinationals," International Tax and Public Finance, Springer, vol. 14(5), pages 605-626, October. [Downloadable!] (restricted)
    Other versions:
  8. Dieter M. Urban, 2006. "Multilateral Investment Agreement in a Political Equilibrium," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich. [Downloadable!]
  9. Marcel Gerard, 2006. "Reforming the taxation of Multijurisdictional Enterprises in Europe, "Coopetition" in a Bottom-up Federation," Working Papers 2006-10, University of Kentucky, Institute for Federalism and Intergovernmental Relations. [Downloadable!]
    Other versions:
  10. Georg Wamser, 2008. "The Impact of Thin-Capitalization Rules on External Debt Usage – A Propensity Score Matching Approach," Ifo Working Paper Series Ifo Working Paper No. 62, Ifo Institute for Economic Research at the University of Munich. [Downloadable!]
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