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Conduit Entities: Implications of Indirect Tax-Efficient Financing Structures for Real Investment

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  • Jack Mintz

Abstract

As well known, companies shift income from high to low tax jurisdictions. Typically, profit shifting is achieved by "direct" financing structures whereby companies use debt finance in the high tax entity and equity finance in the low tax entity. However, certain tax policies can lead to "indirect" financing structures whereby a conduit entity provides an opportunity to achieve at least two deductions for interest expenses for an investment made in the host country. The effect of "direct" and "indirect" financing structures on real investment is compared.

Suggested Citation

  • Jack Mintz, 2004. "Conduit Entities: Implications of Indirect Tax-Efficient Financing Structures for Real Investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 11(4), pages 419-434, August.
  • Handle: RePEc:kap:itaxpf:v:11:y:2004:i:4:p:419-434
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    References listed on IDEAS

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    1. Weichenrieder, Alfons J, 1996. " Transfer Pricing, Double Taxation, and the Cost of Capital," Scandinavian Journal of Economics, Wiley Blackwell, vol. 98(3), pages 445-452.
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    5. Rosanne Altshuler & Jack Mintz, 1995. "U.S. interest-allocation rules: Effects and policy," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 2(1), pages 7-35, February.
    6. Mintz, Jack & Smart, Michael, 2004. "Income shifting, investment, and tax competition: theory and evidence from provincial taxation in Canada," Journal of Public Economics, Elsevier, vol. 88(6), pages 1149-1168, June.
    7. Thomas A. Gresik, 2001. "The Taxing Task of Taxing Transnationals," Journal of Economic Literature, American Economic Association, vol. 39(3), pages 800-838, September.
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    Citations

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    Cited by:

    1. Andreas Haufler & Marco Runkel, 2008. "Firms’ Financial Choices and Thin Capitalization Rules under Corporate Tax Competition," CESifo Working Paper Series 2429, CESifo Group Munich.
    2. 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.
    3. 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.
    4. Daniel Dreßler & Michael Overesch, 2013. "Investment impact of tax loss treatment—empirical insights from a panel of multinationals," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 20(3), pages 513-543, June.
    5. 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.
    6. Schindler, Dirk & Schjelderup, Guttorm, 2012. "Debt shifting and ownership structure," European Economic Review, Elsevier, vol. 56(4), pages 635-647.
    7. Johannesen, Niels, 2012. "Optimal fiscal barriers to international economic integration in the presence of tax havens," Journal of Public Economics, Elsevier, vol. 96(3), pages 400-416.
    8. Hong, Qing & Smart, Michael, 2010. "In praise of tax havens: International tax planning and foreign direct investment," European Economic Review, Elsevier, vol. 54(1), pages 82-95, January.
    9. Keller, Sara & Schanz, Deborah, 2013. "Measuring tax attractiveness across countries," arqus Discussion Papers in Quantitative Tax Research 143, arqus - Arbeitskreis Quantitative Steuerlehre.
    10. Marcel Gérard, 2006. "Reforming the taxation of multijurisdictional enterprises in Europe: a tentative appraisal," European Economy - Economic Papers 2008 - 2015 265, Directorate General Economic and Financial Affairs (DG ECFIN), European Commission.
    11. Fred Ramb & Alfons J. Weichenrieder, 2005. "Taxes and the Financial Structure of German Inward FDI," Review of World Economics (Weltwirtschaftliches Archiv), Springer;Institut für Weltwirtschaft (Kiel Institute for the World Economy), vol. 141(4), pages 670-692, December.
    12. Keller, Sara & Schanz, Deborah, 2013. "Tax attractiveness and the location of German-controlled subsidiaries," arqus Discussion Papers in Quantitative Tax Research 142, arqus - Arbeitskreis Quantitative Steuerlehre.
    13. Dreßler, Daniel, 2012. "Form follows function? Evidence on tax savings by multinational holding structures," ZEW Discussion Papers 12-057, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
    14. Overesch, Michael, 2007. "The Effects of Multinationals? Profit Shifting Activities on Real Investments," ZEW Discussion Papers 07-071, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
    15. Schindler, Dirk & Schjelderup, Guttorm, 2008. "Multinationals, Minority Ownership and Tax-Efficient Financing Structures," Discussion Papers 2008/19, Norwegian School of Economics, Department of Business and Management Science.
    16. Reiter, Franz, 2017. "Avoiding Taxes: Banks' Use of Internal Debt," Annual Conference 2017 (Vienna): Alternative Structures for Money and Banking 168115, Verein für Socialpolitik / German Economic Association.
    17. Harendt, Christoph, 2018. "Tax influence on financial structures of M&As," ZEW Discussion Papers 18-004, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
    18. Alfons J. Weichenrieder & Jack Mintz, 2008. "What determines the use of holding companies and ownership chains?," Working Papers 0803, Oxford University Centre for Business Taxation.
    19. Deborah Schanz & Andreas Dinkel & Sara Keller, 2017. "Tax attractiveness and the location of German-controlled subsidiaries," Review of Managerial Science, Springer, vol. 11(1), pages 251-297, January.

    More about this item

    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

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