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Consequences of the New UK Tax Exemption System: Evidence from Micro-level Data

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  • Peter Egger
  • Valeria Merlo
  • Martin Ruf
  • Georg Wamser

Abstract

Until 2009, the United Kingdom operated a system of worldwide taxation. Taxation of foreign income was deferred until repatriated as dividends, leaving UK-owned multinational firms the possibility of avoiding UK taxation by delaying dividend payments and keeping earnings abroad. In 2009, the UK switched to a system under which all foreign-earned income is exempted from taxation. This fundamental change had a number of straightforward implications for UK-owned multinational firms and particularly changed incentives to repatriate profits. This paper assesses the effects of the reform on the foreign affiliates of UK-owned multinational firms. We use data provided by Bureau van Dijk on 61,738 foreign affiliates located in one of 29 European countries to estimate the impact of the reform on the repatriation pattern and other outcomes of UK-owned affiliates. We use an identification approach that quasi-randomizes over the country of residence of the ultimate firm owners, allowing us to compare outcomes of treated UK-owned foreign affiliates to control non-UK-owned foreign affiliates. Our results suggest that the switch to tax exemption not only changed dividend repatriation behavior of firms but also the conditions under which foreign entities operate in general, for instance, with regard to investment behavior.

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File URL: http://www.cesifo-group.de/portal/page/portal/DocBase_Content/WP/WP-CESifo_Working_Papers/wp-cesifo-2012/wp-cesifo-2012-09/cesifo1_wp3942.pdf
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Bibliographic Info

Paper provided by CESifo Group Munich in its series CESifo Working Paper Series with number 3942.

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Date of creation: 2012
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Handle: RePEc:ces:ceswps:_3942

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Related research

Keywords: UK Tax Reform 2009; tax exemption system; dividend exemption; foreign direct investment;

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References

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  1. Fitzenberger, Bernd & Sommerfeld, Katrin & Steffes, Susanne, 2013. "Causal effects on employment after first birth — A dynamic treatment approach," Labour Economics, Elsevier, vol. 25(C), pages 49-62.
  2. Johannes Becker & Clemens Fuest, 2008. "Tax Competition – Greenfield Investment versus Mergers and Acquisitions," CESifo Working Paper Series 2247, CESifo Group Munich.
  3. Dhammika Dharmapala & C. Fritz Foley & Kristin J. Forbes, 2009. "Watch What I Do, Not What I Say: The Unintended Consequences of the Homeland Investment Act," NBER Working Papers 15023, National Bureau of Economic Research, Inc.
  4. Johannes Becker & Clemens Fuest, 2010. "Taxing Foreign Profits With International Mergers And Acquisitions," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 51(1), pages 171-186, 02.
  5. Harry Grubert & John Mutti, 1995. "Taxing multinationals in a world with portfolio flows and R&D: Is capital export neutrality obsolete?," International Tax and Public Finance, Springer, vol. 2(3), pages 439-457, October.
  6. Richard Blundell & Monica Costa Dias, 2009. "Alternative Approaches to Evaluation in Empirical Microeconomics," Journal of Human Resources, University of Wisconsin Press, vol. 44(3).
  7. Mihir A. Desai & C. Fritz Foley & James R. Hines Jr., 2001. "Repatriation Taxes and Dividend Distortions," NBER Working Papers 8507, National Bureau of Economic Research, Inc.
  8. Michael P. Devereux, 2008. "Taxation of outbound direct investment: economic principles and tax policy considerations," Oxford Review of Economic Policy, Oxford University Press, vol. 24(4), pages 698-719, winter.
  9. Desai, Mihir A. & Hines, James R. Jr., 2003. "Evaluating International Tax Reform," National Tax Journal, National Tax Association, vol. 56(3), pages 487-502, September.
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Cited by:
  1. HASEGAWA Makoto & KIYOTA Kozo, 2013. "The Effect of Moving to a Territorial Tax System on Profit Repatriations: Evidence from Japan," Discussion papers 13047, Research Institute of Economy, Trade and Industry (RIETI).
  2. Estelle P. Dauchy & Sebastien Bradley & Makoto Hasegawa, 2013. "Investor Valuations of Japan's Adoption of a Territorial Tax Regime: Quantifying the Direct and Competitive Effects of International Tax Reform," Working Papers w0201, Center for Economic and Financial Research (CEFIR).

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