IDEAS home Printed from https://ideas.repec.org/p/kud/epruwp/17-02.html
   My bibliography  Save this paper

Taxing multinationals beyond borders: financial and locational responses to CFC rules

Author

Listed:
  • Sarah Clifford

    (Department of Economics, University of Copenhagen)

Abstract

Using a large panel dataset on worldwide operations of multinational firms, this paper studies one of the most advocated anti-tax-avoidance measures: Controlled Foreign Corporation rules. By including income of foreign low-tax subsidiaries in the domestic tax base, these rules create incentives for multinationals to move income away from low-tax environments. Exploiting variation around the tax threshold used to identify low-tax subsidiaries, we find that multinationals redirect profits into subsidiaries just above the threshold and place more new subsidiaries just above compared to just below the threshold. The resulting increase in global corporate tax revenue partly accrues to the rule-enforcing country.

Suggested Citation

  • Sarah Clifford, 2017. "Taxing multinationals beyond borders: financial and locational responses to CFC rules," EPRU Working Paper Series 17-02, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
  • Handle: RePEc:kud:epruwp:17-02
    as

    Download full text from publisher

    File URL: http://web.econ.ku.dk/eprn_epru/Workings_Papers/WP-2017-02.pdf
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. James R. Hines, 2010. "Treasure Islands," Journal of Economic Perspectives, American Economic Association, vol. 24(4), pages 103-126, Fall.
    2. Voget, Johannes, 2011. "Relocation of headquarters and international taxation," Journal of Public Economics, Elsevier, vol. 95(9), pages 1067-1081.
    3. Alfons Weichenrieder, 1996. "Anti-tax-avoidance provisions and the size of foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 3(1), pages 67-81, January.
    4. Barrios, Salvador & Huizinga, Harry & Laeven, Luc & Nicodème, Gaëtan, 2012. "International taxation and multinational firm location decisions," Journal of Public Economics, Elsevier, vol. 96(11), pages 946-958.
    5. Thiess Buettner & Martin Ruf, 2007. "Tax incentives and the location of FDI: Evidence from a panel of German multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 14(2), pages 151-164, April.
    6. Dharmapala, Dhammika & Riedel, Nadine, 2013. "Earnings shocks and tax-motivated income-shifting: Evidence from European multinationals," Journal of Public Economics, Elsevier, vol. 97(C), pages 95-107.
    7. Martin Ruf & Alfons J. Weichenrieder, 2012. "The taxation of passive foreign investment: lessons from German experience," Canadian Journal of Economics, Canadian Economics Association, vol. 45(4), pages 1504-1528, November.
    8. 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.
    9. Gabriel Zucman, 2014. "Taxing across Borders: Tracking Personal Wealth and Corporate Profits," Journal of Economic Perspectives, American Economic Association, vol. 28(4), pages 121-148, Fall.
    10. Devereux, Michael P. & Griffith, Rachel, 1998. "Taxes and the location of production: evidence from a panel of US multinationals," Journal of Public Economics, Elsevier, vol. 68(3), pages 335-367, June.
    11. John H. Mutti & Harry Grubert, 2007. "The Effect of Taxes on Royalties and the Migration of Intangible Assets Abroad," NBER Working Papers 13248, National Bureau of Economic Research, Inc.
    12. Halvorsen, Robert & Palmquist, Raymond, 1980. "The Interpretation of Dummy Variables in Semilogarithmic Equations," American Economic Review, American Economic Association, vol. 70(3), pages 474-475, June.
    13. Rosanne Altshuler & R. Glenn Hubbard, 2002. "The Effect of the Tax Reform Act of 1986 on the Location of Assets," Departmental Working Papers 200012, Rutgers University, Department of Economics.
    14. Voget, Johannes, 2011. "Relocation of headquarters and international taxation," Journal of Public Economics, Elsevier, vol. 95(9-10), pages 1067-1081, October.
    15. Heckemeyer, Jost H. & Overesch, Michael, 2013. "Multinationals' profit response to tax differentials: Effect size and shifting channels," ZEW Discussion Papers 13-045, ZEW - Leibniz Centre for European Economic Research.
    16. Egger, Peter H. & Wamser, Georg, 2015. "The impact of controlled foreign company legislation on real investments abroad. A multi-dimensional regression discontinuity design," Journal of Public Economics, Elsevier, vol. 129(C), pages 77-91.
    17. Michael P Devereux, 2007. "The Impact of Taxation on the Location of Capital, Firms and Profit: a Survey of Empirical Evidence," Working Papers 0702, Oxford University Centre for Business Taxation.
    18. Haufler, Andreas & Mardan, Mohammed & Schindler, Dirk, 2018. "Double tax discrimination to attract FDI and fight profit shifting: The role of CFC rules," Journal of International Economics, Elsevier, vol. 114(C), pages 25-43.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Evers, Andrea & Matthaei, Eva Kristina, 2021. "Steuerplanung unter Unsicherheit: Eine Befragungsstudie zum Brexit," Discussion Papers 2021/10, Free University Berlin, School of Business & Economics.
    2. Lejour, Arjan & Mohlmann, Jan & van't Riet, Maarten & Benschop, Thijs, 2019. "Dutch Shell Companies and International Tax Planning," Discussion Paper 2019-024, Tilburg University, Center for Economic Research.
    3. 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.
    4. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
    5. Bathusi Gabanatlhong & Javier Garcia-Bernardo & Paulinus Iyika & Miroslav Palanský, 2022. "Profit shifting by multinational corporations: Evidence from transaction-level data in Nigeria," WIDER Working Paper Series wp-2022-36, World Institute for Development Economic Research (UNU-WIDER).

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Clifford, Sarah, 2019. "Taxing multinationals beyond borders: Financial and locational responses to CFC rules," Journal of Public Economics, Elsevier, vol. 173(C), pages 44-71.
    2. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
    3. Overesch Michael, 2016. "Steuervermeidung multinationaler Unternehmen," Perspektiven der Wirtschaftspolitik, De Gruyter, vol. 17(2), pages 129-143, July.
    4. Ulrich Schreiber, 2015. "Investitionseffekte des BEPS Aktionsplans der OECD," Schmalenbach Journal of Business Research, Springer, vol. 67(1), pages 102-127, February.
    5. Cooper, Maggie & Nguyen, Quyen T.K., 2020. "Multinational enterprises and corporate tax planning: A review of literature and suggestions for a future research agenda," International Business Review, Elsevier, vol. 29(3).
    6. Arulampalam, Wiji & Devereux, Michael P. & Liberini, Federica, 2019. "Taxes and the location of targets," Journal of Public Economics, Elsevier, vol. 176(C), pages 161-178.
    7. Athiphat Muthitacharoen, 2023. "Location Choice And Tax Responsiveness Of Foreign Multinationals: Evidence From Asean Countries," The Singapore Economic Review (SER), World Scientific Publishing Co. Pte. Ltd., vol. 68(01), pages 217-242, March.
    8. Peter Egger & Michael Stimmelmayr, 2017. "Taxation and the Multinational Firm," CESifo Working Paper Series 6384, CESifo.
    9. 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.
    10. Niels Johannesen & Thomas Tørsløv & Ludvig Wier, 2016. "Are less developed countries more exposed to multinational tax avoidance? Method and evidence from micro-data," WIDER Working Paper Series 010, World Institute for Development Economic Research (UNU-WIDER).
    11. Hoppe, Thomas & Schanz, Deborah & Sturm, Susann & Sureth, Caren & Voget, Johannes, 2020. "The relation between tax complexity and foreign direct investment: Evidence across countries," arqus Discussion Papers in Quantitative Tax Research 250, arqus - Arbeitskreis Quantitative Steuerlehre.
    12. Niels Johannesen & Thomas Tørsløv & Ludvig Wier, 0. "Are Less Developed Countries More Exposed to Multinational Tax Avoidance? Method and Evidence from Micro-Data," The World Bank Economic Review, World Bank, vol. 34(3), pages 790-809.
    13. Niels Johannesen & Thomas Tørsløv & Ludvig Wier, 2016. "Are less developed countries more exposed to multinational tax avoidance? Method and evidence from micro-data," WIDER Working Paper Series 010a, World Institute for Development Economic Research (UNU-WIDER).
    14. Liberini, Federica, 2014. "Corporate Taxes and the Growth of the Firm," The Warwick Economics Research Paper Series (TWERPS) 1042, University of Warwick, Department of Economics.
    15. Bofinger, Peter & Schnabel, Isabel & Feld, Lars P. & Schmidt, Christoph M. & Wieland, Volker, 2014. "Mehr Vertrauen in Marktprozesse. Jahresgutachten 2014/15 [More confidence in market processes. Annual Report 2014/15]," Annual Economic Reports / Jahresgutachten, German Council of Economic Experts / Sachverständigenrat zur Begutachtung der gesamtwirtschaftlichen Entwicklung, volume 127, number 201415.
    16. Niels Johannesen & Thomas Tørsløv & Ludvig Wier, 2016. "Are less developed countries more exposed to multinational tax avoidance? Method and evidence from micro-data," WIDER Working Paper Series 010b (Revised version May, World Institute for Development Economic Research (UNU-WIDER).
    17. von Hagen, Dominik & Harendt, Christoph, 2017. "Impact of controlled foreign corporation rules on post-acquisition investment and profit shifting in targets," ZEW Discussion Papers 17-062, ZEW - Leibniz Centre for European Economic Research.
    18. Keller, Sara & Schanz, Deborah, 2013. "Measuring tax attractiveness across countries," arqus Discussion Papers in Quantitative Tax Research 143, arqus - Arbeitskreis Quantitative Steuerlehre.
    19. Axel Prettl & Dominik Hagen, 2023. "Multinational ownership patterns and anti-tax avoidance legislation," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 30(3), pages 565-634, June.

    More about this item

    Keywords

    CFC legislation; Multinational firms; Tax avoidance; Corporate taxation;
    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

    NEP fields

    This paper has been announced in the following NEP Reports:

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:kud:epruwp:17-02. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Thomas Hoffmann (email available below). General contact details of provider: https://edirc.repec.org/data/epcbsdk.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.