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Taxation and Corporate Group Structure - Evidence from a Sample of European Multinationals


  • Andreas Oestreicher
  • Reinald Koch


We empirically analyze the influence of tax considerations on the structure of investments of a parent company based in one EU member state that holds subsidiaries in a different member state. We show that group taxation, deductibility of financing expenses, or participation write-downs and additional taxes on intragroup dividends may factor into the parent company’s decision on the structure of investments as tax parameters. We find empirical evidence that a vertical structure with a pure holding interposed is implemented more often if a domestic parent entity is required for the formation of a tax group, the semi-elasticities being 0.568 and –0.343.

Suggested Citation

  • Andreas Oestreicher & Reinald Koch, 2012. "Taxation and Corporate Group Structure - Evidence from a Sample of European Multinationals," Schmalenbach Business Review (sbr), LMU Munich School of Management, vol. 64(4), pages 254-280, October.
  • Handle: RePEc:sbr:abstra:v:64:y:2012:i:4:p:254-280

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    References listed on IDEAS

    1. Pedro Ortín-Ángel & Vicente Salas-fumás, 1998. "Agency-Theory and Internal-Labor-Market Explanations of Bonus Payments: Empirical Evidence from Spanish Firms," Journal of Economics & Management Strategy, Wiley Blackwell, vol. 7(4), pages 573-613, December.
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    Cited by:

    1. Keser, Claudia & Kimpel, Gerrit & Oestreicher, Andreas, 2014. "The CCCTB option: An experimental study," Center for European, Governance and Economic Development Research Discussion Papers 199, University of Goettingen, Department of Economics.
    2. Dinkel, Andreas & Schanz, Deborah, 2015. "Tax attractiveness and the location of patents," arqus Discussion Papers in Quantitative Tax Research 188, arqus - Arbeitskreis Quantitative Steuerlehre.
    3. Claudia Keser & Gerrit Kimpel & Andreas Oestreicher, 2014. "The CCCTB option an experimental study," CIRANO Working Papers 2014s-24, CIRANO.
    4. Keser, Claudia & Kimpel, Gerrit & Oestreicher, Andreas, 2014. "The CCCTB option an experimental study," Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100490, Verein für Socialpolitik / German Economic Association.
    5. Claudia Keser & Gerrit Kimpel & Andreas Oestreicher, 2016. "Would a CCCTB mitigate profit shifting?," CIRANO Working Papers 2016s-29, CIRANO.
    6. Rünger, Silke, 2015. "The effect of cross-border group taxation on ownership chains," arqus Discussion Papers in Quantitative Tax Research 194, arqus - Arbeitskreis Quantitative Steuerlehre.

    More about this item


    Corporate Group Structure; Corporate Income Tax; Firm-Level Data; Multinationals;

    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


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