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The Impact of Introducing an Interest Barrier: Evidence from the German Corporation Tax Reform 2008

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  • Hermann Buslei
  • Martin Simmler

Abstract

In this study we investigate the impact of the thin capitalization rule (TCR), introduced in Germany in 2008, on firms' capital structure, investment and profitability. The identification of the causal effects is based on the escape clauses in the regulation using a difference-in-difference approach. Our results present evidence that firms strongly react in order to avoid the limited deductibility of interest expenses: They either decrease their debt ratio or split their assets to use the exemption limit. The latter is especially used by firms with an interest result around the exemption limit of the interest barrier. In case the debt ratio is reduced, our results present evidence for a proportional increase of firms' tax base. In general, in the short term, no negative investment effects are caused by the TCR. This suggests that a part of the firms is able to substitute equity for debt at low costs or expects to be able to circumvent the regulation. However, investment might also be fixed in the short-run for example due to long-lasting contracts.

Suggested Citation

  • Hermann Buslei & Martin Simmler, 2012. "The Impact of Introducing an Interest Barrier: Evidence from the German Corporation Tax Reform 2008," Discussion Papers of DIW Berlin 1215, DIW Berlin, German Institute for Economic Research.
    • Handle: RePEc:diw:diwwpp:dp1215
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    References listed on IDEAS

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    1. Haufler, Andreas & Runkel, Marco, 2012. "Firms' financial choices and thin capitalization rules under corporate tax competition," European Economic Review, Elsevier, vol. 56(6), pages 1087-1103.
    2. 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.
    3. Fuest, Clemens & Hemmelgarn, Thomas, 2005. "Corporate tax policy, foreign firm ownership and thin capitalization," Regional Science and Urban Economics, Elsevier, vol. 35(5), pages 508-526, September.
    4. Fossen, Frank & Simmler, Martin, 2012. "Differential taxation and firms' financial leverage: Evidence from the introduction of a flat tax on interest income," Discussion Papers 2012/4, Free University Berlin, School of Business & Economics.
    5. Buettner, Thiess & Overesch, Michael & Schreiber, Ulrich & Wamser, Georg, 2012. "The impact of thin-capitalization rules on the capital structure of multinational firms," Journal of Public Economics, Elsevier, vol. 96(11), pages 930-938.
    6. Alfons Weichenrieder, 2009. "Profit shifting in the EU: evidence from Germany," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 16(3), pages 281-297, June.
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    Cited by:

    1. Langenmayr, Dominika & Haufler, Andreas & Bauer, Christian J., 2015. "Should tax policy favor high- or low-productivity firms?," European Economic Review, Elsevier, vol. 73(C), pages 18-34.
    2. Mardan, Mohammed, 2017. "Why countries differ in thin capitalization rules: The role of financial development," European Economic Review, Elsevier, vol. 91(C), pages 1-14.
    3. Ruf Martin & Schindler Dirk, 2015. "Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches," Nordic Tax Journal, Sciendo, vol. 2015(1), pages 17-33, September.
    4. Thiess Buettner & Michael Overesch & Georg Wamser, 2018. "Anti profit-shifting rules and foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(3), pages 553-580, June.
    5. Zarko Y. Kalamov, 2020. "Safe haven or earnings stripping rules: a prisoner’s dilemma?," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 27(1), pages 38-76, February.
    6. Nicolay, Katharina & Nusser, Hannah & Pfeiffer, Olena, 2017. "On the interdependency of profit shifting channels and the effectiveness of anti-avoidance legislation," ZEW Discussion Papers 17-066, ZEW - Leibniz Centre for European Economic Research.
    7. Dreßler, Daniel & Scheuering, Uwe, 2012. "Empirical evaluation of interest barrier effects," ZEW Discussion Papers 12-046, ZEW - Leibniz Centre for European Economic Research.
    8. Nora Alice Paulus, 2022. "The anti‐tax‐avoidance directive: An initiative to successfully curb profit shifting?," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 24(3), pages 529-546, June.
    9. Fossen, Frank M. & Simmler, Martin, 2016. "Personal Taxation of Capital Income and the Financial Leverage of Firms," EconStor Open Access Articles and Book Chapters, ZBW - Leibniz Information Centre for Economics, vol. 23(1), pages 48-81.
    10. Alberternst, Stephan & Sureth, Caren, 2015. "The effect of taxes on corporate financing decisions: Evidence from the German interest barrier," arqus Discussion Papers in Quantitative Tax Research 182, arqus - Arbeitskreis Quantitative Steuerlehre.
    11. Jarkko Harju & Ilpo Kauppinen & Olli Ropponen, 2023. "Firm Responses to an Interest Barrier: Empirical Evidence," Working Papers 7, Finnish Centre of Excellence in Tax Systems Research.
    12. Finke, Katharina & Fuest, Clemens & Nusser, Hannah & Spengel, Christoph, 2014. "Extending taxation of interest and royalty income at source: An option to limit base erosion and profit shifting?," ZEW Discussion Papers 14-073, ZEW - Leibniz Centre for European Economic Research.
    13. Alberternst, Stephan & Sureth-Sloane, Caren, 2016. "Interest barrier and capital structure response," arqus Discussion Papers in Quantitative Tax Research 206, arqus - Arbeitskreis Quantitative Steuerlehre.
    14. Dwenger, Nadja & Fossen, Frank M. & Simmler, Martin, 2015. "From financial to real economic crisis: Evidence from individual firm-bank relationships in Germany," Discussion Papers 2015/28, Free University Berlin, School of Business & Economics.
    15. Nadja Dwenger & Frank M Fossen & Martin Simmler, 2015. "From financial to real economic crisis: evidence from individual firm¨Cbank relationships in Germany," Working Papers 1516, Oxford University Centre for Business Taxation.
    16. Jarkko Harju & Ilpo Kauppinen & Olli Ropponen, 2017. "Firm Responses to an Interest Barrier: Empirical Evidence," EconPol Working Paper 3, ifo Institute - Leibniz Institute for Economic Research at the University of Munich.
    17. Ropponen, Olli, 2021. "Interest Limitation Rules and Business Cycles: Empirical Evidence," ETLA Working Papers 90, The Research Institute of the Finnish Economy.
    18. Zarko Y. Kalamov, 2023. "Internal debt and welfare," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 25(1), pages 196-224, February.

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    More about this item

    Keywords

    Thin capitalization; earnings stripping rule; debt ratio; profitability; investment;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • G32 - Financial Economics - - Corporate Finance and Governance - - - Financing Policy; Financial Risk and Risk Management; Capital and Ownership Structure; Value of Firms; Goodwill

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