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The Three Parties in the Race to the Bottom: Host Governments, Home Governments and Multinational Companies

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  • Rosanne Altshuler

    ()
    (Rutgers University, Department of Economics)

  • Harry Grubert

    ()
    (U.S. Treasury Department, Office of Tax Analysis)

Abstract

Most studies of tax competition and the race to the bottom focus on potential host countries competing for mobile capital, neglecting the role of corporate tax planning and of home governments that facilitate this planning. This neglect in part reflects the narrow view frequently taken of the policy instruments that countries have available in tax competition. For example, high-tax host governments can permit income to be shifted out to tax havens as a way of attracting mobile companies. Home countries will cooperate in this shift if they think the benefit to their companies is greater than any reduction in the domestic tax base. We use various types of U.S. data, including firm level tax files, to identify the role of the three parties (host governments, home governments and MNCs) in the evolution of tax burdens on U.S. companies abroad from1992 to 2002. This period is of particular interest because the United States introduced regulations in 1997 that greatly simplified the use of more aggressive tax planning techniques. The evidence indicates that from 1992 to 1998 the decline in effective tax rates on U.S. companies was driven largely by host governments defending their market share. But after 1998, tax avoidance behavior seems much more important. Effective tax rates on U.S. companies had a much weaker link with local statutory tax rates. Furthermore, the disparity in the reported profitability of subsidiaries in high-tax and low-tax jurisdictions grew substantially. After 1997, there was a very large growth in intercompany payments and a parallel growth of holding company income. We attempt to estimate how much of these payments were deductible in the host country, and conclude that by 2002 the companies were saving about $7.0 billion per year by using the more aggressive planning strategies. This amounts to about 4 percent of foreign direct investment income and about 15 percent of their foreign tax burden.

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Bibliographic Info

Paper provided by Rutgers University, Department of Economics in its series Departmental Working Papers with number 200625.

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Length: 20 pages
Date of creation: 24 Nov 2006
Date of revision:
Handle: RePEc:rut:rutres:200625

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References

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  1. Rosanne Altshuler & Harry Grubert, 2001. "Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy," NBER Working Papers 8144, National Bureau of Economic Research, Inc.
  2. Rosanne Altshuler & Harry Grubert, 2004. "Taxpayer Responses to Competitive Tax Policies and Tax Policy Responses to Competitive Taxpayers: Recent Evidence," Departmental Working Papers 200406, Rutgers University, Department of Economics.
  3. Grubert, Harry & Mutti, John, 1991. "Taxes, Tariffs and Transfer Pricing in Multinational Corporate Decision Making," The Review of Economics and Statistics, MIT Press, vol. 73(2), pages 285-93, May.
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Cited by:
  1. Rosanne Altshuler & Alan Auerbach & Michael Cooper & Matthew Knittel, 2011. "Understanding U.S. Corporate Tax Losses," Departmental Working Papers 201124, Rutgers University, Department of Economics.
  2. Harry Grubert, 2009. "Foreign Taxes, Domestic Income, and the Jump in the Share of Multinational Company Income Abroad," Working Papers 0926, Oxford University Centre for Business Taxation.
  3. Francoise Forges & Frederic Koessler, 2006. "Long Persuasion Games," THEMA Working Papers 2006-01, THEMA (THéorie Economique, Modélisation et Applications), Université de Cergy-Pontoise.
  4. Dhammika Dharmapala, 2008. "What problems and opportunities are created by tax havens?," Oxford Review of Economic Policy, Oxford University Press, vol. 24(4), pages 661-679, winter.
  5. Neils Johannesen, 2012. "Strategic Line Drawing between Debt and Equity," Working Papers 1203, Oxford University Centre for Business Taxation.
  6. Rosanne Altshuler & Timothy J. Goodspeed, 2002. "Follow the Leader? Evidence on European and U.S. Tax Competition," Departmental Working Papers 200226, Rutgers University, Department of Economics.
  7. Niels Johannesen, 2012. "Cross-border hybrid instruments," EPRU Working Paper Series 2012-02, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
  8. Julian Alworth & Giampaolo Arachi, 2008. "Taxation Policy in EMU - Julian Alworth and Giampaolo Arachi," European Economy - Economic Papers 310, Directorate General Economic and Monetary Affairs (DG ECFIN), European Commission.

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