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Do US Firms Pay Less Tax than their European Peers? On Firm Characteristics, Profit Shifting Opportunities, and Tax Legislation as Determinants of Tax Differentials

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  • Michael Overesch
  • Sabine Schenkelberg
  • Georg Wamser

Abstract

Using pairs of similar US and European firms listed on the S&P500 or StoxxEurope600, we examine effective tax differentials between US multinational corporations (MNCs) and their European peers. We show that statutory tax rates and profit shifting opportunities are important determinants of effective tax rates. Our findings suggest substantially lower total tax payments of US MNCs after the 2017 US tax reform. Based on past reforms of Controlled Foreign Company (CFC) rules and of the principle of worldwide taxation, we confirm that international tax legislation affects effective tax expenses. We also provide evidence for heterogeneity in firm responses: MNCs with profit shifting opportunities benefit most from more-lenient CFC rules.

Suggested Citation

  • Michael Overesch & Sabine Schenkelberg & Georg Wamser, 2018. "Do US Firms Pay Less Tax than their European Peers? On Firm Characteristics, Profit Shifting Opportunities, and Tax Legislation as Determinants of Tax Differentials," CESifo Working Paper Series 6960, CESifo.
  • Handle: RePEc:ces:ceswps:_6960
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    References listed on IDEAS

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    1. Bräutigam, Rainer & Spengel, Christoph & Streif, Frank, 2015. "Decline of CFC rules and rise of IP boxes: How the ECJ affects tax competition and economic distortions in Europe," ZEW Discussion Papers 15-055, ZEW - Leibniz Centre for European Economic Research.
    2. Hasegawa, Makoto & Kiyota, Kozo, 2017. "The effect of moving to a territorial tax system on profit repatriation: Evidence from Japan," Journal of Public Economics, Elsevier, vol. 153(C), pages 92-110.
    3. Buettner, Thiess & Wamser, Georg, 2013. "Internal Debt and Multinational Profit Shifting: Empirical Evidence From Firm-Level Panel Data," National Tax Journal, National Tax Association;National Tax Journal, vol. 66(1), pages 63-95, March.
    4. Huizinga, Harry & Laeven, Luc & Nicodeme, Gaetan, 2008. "Capital structure and international debt shifting," Journal of Financial Economics, Elsevier, vol. 88(1), pages 80-118, April.
    5. Huizinga, Harry & Laeven, Luc, 2008. "International profit shifting within multinationals: A multi-country perspective," Journal of Public Economics, Elsevier, vol. 92(5-6), pages 1164-1182, June.
    6. Ronald B. Davies & Julien Martin & Mathieu Parenti & Farid Toubal, 2018. "Knocking on Tax Haven’s Door: Multinational Firms and Transfer Pricing," The Review of Economics and Statistics, MIT Press, vol. 100(1), pages 120-134, March.
    7. Harris, Dg, 1993. "The Impact Of United-States Tax-Law Revision On Multinational-Corporations Capital Location And Income-Shifting Decisions," Journal of Accounting Research, Wiley Blackwell, vol. 31, pages 111-140.
    8. Peter Egger & Valeria Merlo & Martin Ruf & Georg Wamser, 2015. "Consequences of the New UK Tax Exemption System: Evidence from Micro‐level Data," Economic Journal, Royal Economic Society, vol. 125(589), pages 1764-1789, December.
    9. Desai, Mihir A. & Foley, C. Fritz & Hines, James Jr., 2006. "The demand for tax haven operations," Journal of Public Economics, Elsevier, vol. 90(3), pages 513-531, February.
    10. Martin Ruf & Alfons J. Weichenrieder, 2012. "The taxation of passive foreign investment: lessons from German experience," Canadian Journal of Economics/Revue canadienne d'économique, John Wiley & Sons, vol. 45(4), pages 1504-1528, November.
    11. Plesko, George A., 2003. "An evaluation of alternative measures of corporate tax rates," Journal of Accounting and Economics, Elsevier, vol. 35(2), pages 201-226, June.
    12. Martin Ruf & Alfons J. Weichenrieder & Alfons Weichenrieder, 2013. "CFC Legislation, Passive Assets and the Impact of the ECJ's Cadbury-Schweppes Decision," CESifo Working Paper Series 4461, CESifo.
    13. Anca D. Cristea & Daniel X. Nguyen, 2016. "Transfer Pricing by Multinational Firms: New Evidence from Foreign Firm Ownerships," American Economic Journal: Economic Policy, American Economic Association, vol. 8(3), pages 170-202, August.
    14. James R. Hines & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, President and Fellows of Harvard College, vol. 109(1), pages 149-182.
    15. Dyreng, Scott D. & Hanlon, Michelle & Maydew, Edward L. & Thornock, Jacob R., 2017. "Changes in corporate effective tax rates over the past 25 years," Journal of Financial Economics, Elsevier, vol. 124(3), pages 441-463.
    16. Gupta, Sanjay & Newberry, Kaye, 1997. "Determinants of the variability in corporate effective tax rates: Evidence from longitudinal data," Journal of Accounting and Public Policy, Elsevier, vol. 16(1), pages 1-34.
    17. Grubert, Harry, 2003. "Intangible Income, Intercompany Transactions, Income Shifting, and the Choice of Location," National Tax Journal, National Tax Association;National Tax Journal, vol. 56(1), pages 221-242, March.
    18. James Heckman & Hidehiko Ichimura & Jeffrey Smith & Petra Todd, 1998. "Characterizing Selection Bias Using Experimental Data," Econometrica, Econometric Society, vol. 66(5), pages 1017-1098, September.
    19. Marco Caliendo & Sabine Kopeinig, 2008. "Some Practical Guidance For The Implementation Of Propensity Score Matching," Journal of Economic Surveys, Wiley Blackwell, vol. 22(1), pages 31-72, February.
    20. Jost H. Heckemeyer & Michael Overesch, 2017. "Multinationals profit response to tax differentials: Effect size and shifting channels," Canadian Journal of Economics, Canadian Economics Association, vol. 50(4), pages 965-994, November.
    21. Kevin Markle, 2016. "A Comparison of the Tax†Motivated Income Shifting of Multinationals in Territorial and Worldwide Countries," Contemporary Accounting Research, John Wiley & Sons, vol. 33(1), pages 7-43, March.
    22. Grubert, Harry, 2012. "Foreign Taxes and the Growing Share of U.S. Multinational Company Income Abroad: Profits, Not Sales, Are Being Globalized," National Tax Journal, National Tax Association;National Tax Journal, vol. 65(2), pages 247-281, June.
    23. Richardson, Grant & Lanis, Roman, 2007. "Determinants of the variability in corporate effective tax rates and tax reform: Evidence from Australia," Journal of Accounting and Public Policy, Elsevier, vol. 26(6), pages 689-704.
    24. Hanlon, Michelle & Slemrod, Joel, 2009. "What does tax aggressiveness signal? Evidence from stock price reactions to news about tax shelter involvement," Journal of Public Economics, Elsevier, vol. 93(1-2), pages 126-141, February.
    25. Hanlon, Michelle & Heitzman, Shane, 2010. "A review of tax research," Journal of Accounting and Economics, Elsevier, vol. 50(2-3), pages 127-178, December.
    26. Augurzky, Boris & Schmidt, Christoph M., 2001. "The Propensity Score: A Means to An End," IZA Discussion Papers 271, Institute of Labor Economics (IZA).
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    Cited by:

    1. Bricongne, Jean-Charles & Delpeuch, Samuel & Lopez-Forero, Margarita, 2023. "Productivity slowdown and tax havens: Where is measured value creation?," Journal of International Economics, Elsevier, vol. 143(C).
    2. Sabine Schenkelberg, 2020. "The Cadbury Schweppes judgment and its implications on profit shifting activities within Europe," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 27(1), pages 1-31, February.
    3. Giese, Henning & Koch, Reinald & Gamm, Markus, 2022. "Tax avoidance and vertical interlocks within multinational enterprises," arqus Discussion Papers in Quantitative Tax Research 270, arqus - Arbeitskreis Quantitative Steuerlehre.
    4. Petr Janský, 2023. "Corporate Effective Tax Rates for Research and Policy," Public Finance Review, , vol. 51(2), pages 171-205, March.
    5. Chen, Xikai & Lu, Meiting & Shan, Yaowen, 2020. "Changes in corporate effective tax rates during three decades in Japan," Pacific-Basin Finance Journal, Elsevier, vol. 62(C).

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    More about this item

    Keywords

    effective tax rate; tax avoidance; tax reform; CFC rule; international taxation; pair matching; difference-in-differences analysis;
    All these keywords.

    JEL classification:

    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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