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Investment and Financing Strategy of a Multinational Enterprise under Alternative Tax Designs

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  • Marcel Gérard
  • Savina Princen

Abstract

This paper investigates the consequences of a series of alternative international tax designs on the strategy of a multinational enterprise regarding the cross border distribution of its investment and the choice of its financing behavior. We start with a world where no international tax rules are at work. Then we successively introduce (i) the rules provided by the OECD Model Tax Convention, (ii) the EU Parent-Subsidiary Directive of July 23, 1990; and (iii) a combination of Allowance for Corporate Equity (ACE) and Comprehensive Business Income Tax (CBIT). Finally, we leave systems based on Separate Accounting (SA) aside and turn to Consolidation and Formulary Apportionment (C&FA) adopted either by all the jurisdictions at work in the model, or by a sole subset of them within the framework of an Enhanced Cooperation Agreement (ECA).

Suggested Citation

  • Marcel Gérard & Savina Princen, 2012. "Investment and Financing Strategy of a Multinational Enterprise under Alternative Tax Designs," CESifo Working Paper Series 3838, CESifo.
    • Handle: RePEc:ces:ceswps:_3838
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    References listed on IDEAS

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    Cited by:

    1. Kayis-Kumar, Ann, 2015. "Thin capitalisation rules: A second-best solution to the cross-border debt bias?," MPRA Paper 72031, University Library of Munich, Germany.
    2. Ortmann, Regina, 2015. "Uncertainty in weighting formulary apportionment factors and its impact on after-tax income of multinational groups," arqus Discussion Papers in Quantitative Tax Research 184, arqus - Arbeitskreis Quantitative Steuerlehre.
    3. Ortmann, Regina & Sureth, Caren, 2014. "Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?," arqus Discussion Papers in Quantitative Tax Research 165, arqus - Arbeitskreis Quantitative Steuerlehre.
    4. Kayis-Kumar, Ann, 2015. "Taxing cross-border intercompany transactions: are financing activities fungible?," MPRA Paper 71615, University Library of Munich, Germany.
    5. Fabien Candau & Jacques Le Cacheux, 2018. "Taming Tax Competition with a European Corporate Income Tax," Revue d'économie politique, Dalloz, vol. 128(4), pages 575-611.
    6. Regina Ortmann & Caren Sureth-Sloane, 2016. "Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?," Journal of Business Economics, Springer, vol. 86(5), pages 441-475, July.

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    More about this item

    Keywords

    corporate tax; multinational firms; MNE;
    All these keywords.

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law

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