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Tax treaty shopping: structural determinants of Foreign Direct Investment routed through the Netherlands

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  • Francis Weyzig

Abstract

Many multinationals divert Foreign Direct Investment (FDI) through conduit countries that have a favorable tax treaty network, to avoid host country withholding taxes. This is referred to as tax treaty shopping. The Netherlands is the world’s largest conduit country; in 2009, multinationals held approximately €1,600 billion of FDI via the Netherlands. This paper uses microdata from Dutch Special Purpose Entities to analyze geographical patterns and structural determinants of FDI diversion. Regression analysis confirms that tax treaties are a key determinant of FDI routed through the Netherlands. The effect of tax treaties on FDI diversion partly arises from the reduction of dividend withholding tax rates, which provides strong evidence for tax treaty shopping. Copyright Springer Science+Business Media, LLC 2013

Suggested Citation

  • Francis Weyzig, 2013. "Tax treaty shopping: structural determinants of Foreign Direct Investment routed through the Netherlands," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 20(6), pages 910-937, December.
  • Handle: RePEc:kap:itaxpf:v:20:y:2013:i:6:p:910-937
    DOI: 10.1007/s10797-012-9250-z
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    References listed on IDEAS

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    More about this item

    Keywords

    Treaty shopping; Tax treaties; Foreign direct investment; Withholding tax; Special purpose entities; G32; H25; H32;
    All these keywords.

    JEL classification:

    • G32 - Financial Economics - - Corporate Finance and Governance - - - Financing Policy; Financial Risk and Risk Management; Capital and Ownership Structure; Value of Firms; Goodwill
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H32 - Public Economics - - Fiscal Policies and Behavior of Economic Agents - - - Firm

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