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Taxation and the Financial Structure of Foreign Direct Investment

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Author Info
Frances Ruane
Padraig Moore

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Abstract

The vast increase in foreign assets globally has raised interest in how the home country should tax profits flowing from these investments. Broadly speaking, countries have chosen either to exempt foreign income from taxation or to subject foreign income to taxation with credits/deductions given for foreign taxes paid. Recent research has focused on the effect of these foreign income tax rules on the relationship between aggregate FDI flows and corporate tax rates. In this paper we examine how foreign income tax rules can affect the financial structure of subsidiary-level FDI in Europe. The tax-deductibility of interest payments suggests that higher (host-country) corporate tax rates should be associated with a greater proportion of debt-financed FDI, as foreign income tax credit systems should, in theory, limit the benefits of shielding foreign income from host country taxation. Our results indicate that whilst multinationals from tax exemption countries adjust the financial structure of foreign investments in response to corporate tax rates, the effect of corporate tax rates is insignificant for FDI originating from tax credit countries. These results reveal an additional channel through which foreign income tax credit systems attenuate the forces of tax competition.

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Paper provided by IIIS in its series The Institute for International Integration Studies Discussion Paper Series with number iiisdp88.

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Date of creation: 15 Dec 2005
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Handle: RePEc:iis:dispap:iiisdp88

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Find related papers by JEL classification:
F21 - International Economics - - International Factor Movements and International Business - - - International Investment; Long-Term Capital Movements
F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods
F36 - International Economics - - International Finance - - - Financial Aspects of Economic Integration
G32 - Financial Economics - - Corporate Finance and Governance - - - Financing Policy; Capital and Ownership Structure

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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. Mervyn A. King & Don Fullerton, 1983. "The Taxation of Income from Capital: A Comparative Study of the U.S., U.K., Sweden, and West Germany--The Theoretical Framework--," NBER Working Papers 1058, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  2. Huizinga, Harry & Nicodeme, Gaetan, 2003. "Foreign Ownership and Corporate Income Taxation: An Empirical Evaluation," CEPR Discussion Papers 3952, C.E.P.R. Discussion Papers. [Downloadable!] (restricted)
    Other versions:
  3. Mihir A. Desai & C. Fritz Foley & James R. Hines, Jr., 2003. "A Multinational Perspective on Capital Structure Choice and Internal Capital Markets," NBER Working Papers 9715, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
    Other versions:
  4. 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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  5. Reint Gropp & Kristina Kostial, 2000. "The disappearing tax base: is foreign direct investment eroding corporate income taxes?," Working Paper Series 31, European Central Bank. [Downloadable!]
  6. Rosanne Altshuler & Harry Grubert, 2002. "Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy," Departmental Working Papers 200009, Rutgers University, Department of Economics. [Downloadable!]
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  7. Nicodeme, G., 2001. "Computing Effective Corporate Tax Rates: Comparisons and Results," European Economy - Economic Papers 153, Commission of the EC, Directorate-General for Economic and Financial Affairs (DG ECFIN).
    Other versions:
  8. de Mooij, Ruud A & Ederveen, Sjef, 2003. "Taxation and Foreign Direct Investment: A Synthesis of Empirical Research," International Tax and Public Finance, Springer, vol. 10(6), pages 673-93, November. [Downloadable!] (restricted)
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  9. Gomez-Salvador, Ramon & Messina, Julian & Vallanti, Giovanna, 2004. "Gross job flows and institutions in Europe," Labour Economics, Elsevier, vol. 11(4), pages 469-485, August. [Downloadable!] (restricted)
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  10. 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. [Downloadable!] (restricted)
  11. James R. Hines, Jr., 1996. "Tax Policy and the Activities of Multinational Corporations," NBER Working Papers 5589, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
  12. Mihir Desai & Paul Gompers & Josh Lerner, 2003. "Institutions, Capital Constraints and Entrepreneurial Firm Dynamics: Evidence from Europe," NBER Working Papers 10165, National Bureau of Economic Research, Inc. [Downloadable!] (restricted)
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  1. Huizinga, Harry & Laeven, Luc & Nicodeme, Gaetan, 2006. "Capital Structure and International Debt Shifting," CEPR Discussion Papers 5882, C.E.P.R. Discussion Papers. [Downloadable!] (restricted)
    Other versions:
  2. Gaetan Nicodeme, 2009. "Corporate Income Tax and Economic Distortions," Taxation Papers 15, Directorate General Taxation and Customs Union, European Commission, revised Apr 2009. [Downloadable!]
    Other versions:
  3. Christian Keuschnigg & Peter Egger & Wolfgang Eggert & Hannes Winner, 2009. "Corporate Taxation, Debt Financing and Foreign Plant Ownership," University of St. Gallen Department of Economics working paper series 2009 2009-01, Department of Economics, University of St. Gallen. [Downloadable!]
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