Form follows function? Evidence on tax savings by multinational holding structures
AbstractI provide evidence on the group structures of multinationals and analyze to what extent these structures are tax efficient. While the corporate income tax can hardly be avoided if a subsidiary is active in a country, withholding taxes depend on the structure in which the subsidiary is embedded. By vertically inserting holding companies or adjusting the superior/subordinate relationship of subsidiaries, multinationals can often influence their total tax burden, especially regarding the repatriation of profits by means of dividends. I analyze group structures across 58 countries in the years 1996 to 2008 using the MiDi database provided by the German Central Bank (Deutsche Bundesbank). The results show that a higher withholding tax between two members of a group located in different countries increases the probability of indirect participation. However, in about half of the observations, the existence of an intermediate subsidiary does not lower the overall tax burden, and in 5% of the cases the tax burden on repatriated profits with such a holding company is even higher than without it. Although group structures generally seem to be tax driven, there are non-tax influencing factors which sometimes prevail. Besides drivers of the vertical company structure, I provide evidence of a horizontal driver: once a form of group taxation is available, groups seem to spread their national investments across more subsidiaries. --
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Bibliographic InfoPaper provided by ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research in its series ZEW Discussion Papers with number 12-057.
Date of creation: 2012
Date of revision:
Corporate Taxation; Foreign Direct Investment; Holdings; Multinational Firms; Withholding Taxes;
Find related papers by 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
- H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm
This paper has been announced in the following NEP Reports:
- NEP-ACC-2012-11-24 (Accounting & Auditing)
- NEP-ALL-2012-11-24 (All new papers)
- NEP-PBE-2012-11-24 (Public Economics)
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- Hines, J.R. & Rice, E.M., 1990.
"Fiscal Paradise: Foreign Tax Havens And American Business,"
56, Princeton, Woodrow Wilson School - Discussion Paper.
- Hines, James R, Jr & Rice, Eric M, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, MIT Press, vol. 109(1), pages 149-82, February.
- James R. Hines, Jr. & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," NBER Working Papers 3477, National Bureau of Economic Research, Inc.
- Hines, James Jr., 1994.
"Credit and deferral as international investment incentives,"
Journal of Public Economics,
Elsevier, vol. 55(2), pages 323-347, October.
- James R. Hines Jr., 1994. "Credit and Deferral as International Investment Incentives," NBER Working Papers 4191, National Bureau of Economic Research, Inc.
- Mintz, J. & Tulkens, H., .
"Optimality properties of alternative systems of taxation of foreign capital income,"
CORE Discussion Papers RP
-1212, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
- Mintz, Jack & Tulkens, Henry, 1996. "Optimality properties of alternative systems of taxation of foreign capital income," Journal of Public Economics, Elsevier, vol. 60(3), pages 373-399, June.
- MINTZ, Jacques & TULKENS , Henry, 1994. "Optimality Properties of Alternative Systems of Taxation of Foreign Capital Income," CORE Discussion Papers 1994078, Université catholique de Louvain, Center for Operations Research and Econometrics (CORE).
- Dhammika Dharmapala & James R. Hines Jr., 2006.
"Which Countries Become Tax Havens?,"
NBER Working Papers
12802, National Bureau of Economic Research, Inc.
- Rosanne Altshuler & Harry Grubert, 2002.
"Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy,"
Departmental Working Papers
200009, Rutgers University, Department of Economics.
- Altshuler, Rosanne & Grubert, Harry, 2003. "Repatriation taxes, repatriation strategies and multinational financial policy," Journal of Public Economics, Elsevier, vol. 87(1), pages 73-107, January.
- Rosanne Altshuler & Harry Grubert, 2001. "Repatriation Taxes, Repatriation Strategies and Multinational Financial Policy," NBER Working Papers 8144, National Bureau of Economic Research, Inc.
- Jack M. Mintz, 2003.
"Conduit Entities: Implications of Indirect Tax-Efficient Financing Structures for Real Investment,"
International Tax Program Papers
0410, International Tax Program, Institute for International Business, Joseph L. Rotman School of Management, University of Toronto, revised Sep 2004.
- Jack Mintz, 2004. "Conduit Entities: Implications of Indirect Tax-Efficient Financing Structures for Real Investment," International Tax and Public Finance, Springer, vol. 11(4), pages 419-434, 08.
- 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.
- Ruud A. de Mooij & Sjef Ederveen, 2001. "Taxation and Foreign Direct Investment: A Synthesis of Empirical Research," CESifo Working Paper Series 588, CESifo Group Munich.
- Ruud de Mooij & S. Ederveen, 2001. "Taxation and foreign direct investment; a synthesis of empirical research," CPB Discussion Paper 3, CPB Netherlands Bureau for Economic Policy Analysis.
- Thomas Dickescheid, 2004. "Exemption vs. Credit Method in International Double Taxation Treaties," International Tax and Public Finance, Springer, vol. 11(6), pages 721-739, November.
- Donald W.K. Andrews & Moshe Y. Buchinsky, 2000.
"On the Number of Bootstrap Repetitions for BC_a Confidence Intervals,"
Cowles Foundation Discussion Papers
1250, Cowles Foundation for Research in Economics, Yale University.
- Andrews, Donald W.K. & Buchinsky, Moshe, 2002. "ON THE NUMBER OF BOOTSTRAP REPETITIONS FOR BCa CONFIDENCE INTERVALS," Econometric Theory, Cambridge University Press, vol. 18(04), pages 962-984, August.
- Donald W.K. Andrews & Moshe Buchinsky, 1999. "On the Number of Bootstrap Repetitions for Bca Confidence Intervals," Working Papers 99-17, Brown University, Department of Economics.
- Janeba, Eckhard, 1995.
"Corporate income tax competition, double taxation treaties, and foreign direct investment,"
Journal of Public Economics,
Elsevier, vol. 56(2), pages 311-325, February.
- Janeba,Eckhard, 1991. "Corporate income tax competition,Double taxation treaties, and foreign direct investment," Discussion Paper Serie A 361, University of Bonn, Germany.
- Johannes Becker & Clemens Fuest, 2007. "Why is there Corporate Taxation? The Role of Limited Liability Revisited," Journal of Economics, Springer, vol. 92(1), pages 1-10, September.
- 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.
- Desai, Mihir A. & Foley, C. Fritz & Hines, James Jr., 2006. "Do tax havens divert economic activity?," Economics Letters, Elsevier, vol. 90(2), pages 219-224, February.
- Mintz, Jack M. & Weichenrieder, Alfons J., 2010. "The Indirect Side of Direct Investment: Multinational Company Finance and Taxation," MIT Press Books, The MIT Press, edition 1, volume 1, number 0262014491, January.
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