IDEAS home Printed from https://ideas.repec.org/a/ucp/nattax/doi10.1086-727012.html
   My bibliography  Save this article

Territorial Tax Reform and Profit Shifting by US and Japanese Multinationals

Author

Listed:
  • Makoto Hasegawa

Abstract

In 2009, Japan adopted a territorial tax regime by exempting dividends paid by Japanese-owned foreign subsidiaries to their parent firms from home-country taxation. This paper examines the impact of this tax reform on profit shifting by Japanese multinationals. I find that the semielasticity of pretax profits with respect to host-country corporate tax rates for Japanese-owned foreign subsidiaries, particularly large subsidiaries, increased after the 2008 announcement of the implementation of the territorial tax regime, relative to that for US-owned foreign subsidiaries. This suggests that large Japanese-owned foreign subsidiaries responded to the incentive for profit shifting provided by the territorial tax reform.

Suggested Citation

  • Makoto Hasegawa, 2023. "Territorial Tax Reform and Profit Shifting by US and Japanese Multinationals," National Tax Journal, University of Chicago Press, vol. 76(4), pages 771-804.
    • Handle: RePEc:ucp:nattax:doi:10.1086/727012
    DOI: 10.1086/727012
    as

    Download full text from publisher

    File URL: http://dx.doi.org/10.1086/727012
    Download Restriction: Access to the online full text or PDF requires a subscription.
    File URL: http://dx.doi.org/10.1086/727012
    Download Restriction: Access to the online full text or PDF requires a subscription.
    File URL: https://libkey.io/10.1086/727012?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    As the access to this document is restricted, you may want to look for a different version below or search for a different version of it.

    Other versions of this item:

    References listed on IDEAS

    as
    1. Karkinsky, Tom & Riedel, Nadine, 2012. "Corporate taxation and the choice of patent location within multinational firms," Journal of International Economics, Elsevier, vol. 88(1), pages 176-185.
    2. Sebastien Bradley & Estelle Dauchy & Makoto Hasegawa, 2018. "Investor valuations of Japan’s adoption of a territorial tax regime: quantifying the direct and competitive effects of international tax reform," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(3), pages 581-630, June.
    3. Hasegawa, Makoto & Kiyota, Kozo, 2017. "The effect of moving to a territorial tax system on profit repatriation: Evidence from Japan," Journal of Public Economics, Elsevier, vol. 153(C), pages 92-110.
    4. Huizinga, Harry & Laeven, Luc, 2008. "International profit shifting within multinationals: A multi-country perspective," Journal of Public Economics, Elsevier, vol. 92(5-6), pages 1164-1182, June.
    5. Bodo Knoll & Nadine Riedel, 2015. "Transfer Pricing Laws," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(4), pages 22-26, 01.
    6. Dharmapala, Dhammika & Riedel, Nadine, 2013. "Earnings shocks and tax-motivated income-shifting: Evidence from European multinationals," Journal of Public Economics, Elsevier, vol. 97(C), pages 95-107.
    7. repec:ces:ifodic:v:12:y:2015:i:4:p:19149986 is not listed on IDEAS
    8. Li Liu & Tim Schmidt-Eisenlohr & Dongxian Guo, 2020. "International Transfer Pricing and Tax Avoidance: Evidence from Linked Trade-Tax Statistics in the United Kingdom," The Review of Economics and Statistics, MIT Press, vol. 102(4), pages 766-778, October.
    9. Clausing, Kimberly A., 2003. "Tax-motivated transfer pricing and US intrafirm trade prices," Journal of Public Economics, Elsevier, vol. 87(9-10), pages 2207-2223, September.
    10. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
    11. Xing, Jing, 2018. "Territorial tax system reform and multinationals' foreign cash holdings: New evidence from Japan," Journal of Corporate Finance, Elsevier, vol. 49(C), pages 252-282.
    12. Dhammika Dharmapala, 2014. "What Do We Know about Base Erosion and Profit Shifting? A Review of the Empirical Literature," Fiscal Studies, Institute for Fiscal Studies, vol. 35, pages 421-448, December.
    13. Dominika Langenmayr & Li Liu, 2020. "Where Does Multinational Profit Go with Territorial Taxation? Evidence from the UK," CESifo Working Paper Series 8047, CESifo.
    14. Kimberly A. Clausing, 2020. "Profit Shifting before and after the Tax Cuts and Jobs Act," National Tax Journal, National Tax Association;National Tax Journal, vol. 73(4), pages 1233-1266, December.
    15. Preetika Joshi, 2020. "Does Private Country‐by‐Country Reporting Deter Tax Avoidance and Income Shifting? Evidence from BEPS Action Item 13," Journal of Accounting Research, Wiley Blackwell, vol. 58(2), pages 333-381, May.
    16. Anca D. Cristea & Daniel X. Nguyen, 2016. "Transfer Pricing by Multinational Firms: New Evidence from Foreign Firm Ownerships," American Economic Journal: Economic Policy, American Economic Association, vol. 8(3), pages 170-202, August.
    17. James R. Hines & Eric M. Rice, 1994. "Fiscal Paradise: Foreign Tax Havens and American Business," The Quarterly Journal of Economics, President and Fellows of Harvard College, vol. 109(1), pages 149-182.
    18. Molly J. Saunders-Scott, 2015. "Substitution Across Methods of Profit Shifting," National Tax Journal, National Tax Association;National Tax Journal, vol. 68(4), pages 1099-1120, December.
    19. Hines, James R. Jr., 1999. "Lessons From Behavioral Responses to International Taxation," National Tax Journal, National Tax Association;National Tax Journal, vol. 52(2), pages 305-322, June.
    20. Jacob, J, 1996. "Taxes and transfer pricing: Income shifting and the volume of intrafirm transfers," Journal of Accounting Research, Wiley Blackwell, vol. 34(2), pages 301-312.
    21. 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 285-293, May.
    22. Dowd, Tim & Landefeld, Paul & Moore, Anne, 2017. "Profit shifting of U.S. multinationals," Journal of Public Economics, Elsevier, vol. 148(C), pages 1-13.
    23. Dhammika Dharmapala, 2018. "The Consequences of the Tax Cut and Jobs Act's International Provisions: Lessons from Existing Research," National Tax Journal, National Tax Association;National Tax Journal, vol. 71(4), pages 707-728, December.
    24. Li Liu, 2020. "Where Does Multinational Investment Go with Territorial Taxation? Evidence from the United Kingdom," American Economic Journal: Economic Policy, American Economic Association, vol. 12(1), pages 325-358, February.
    25. Jost H. Heckemeyer & Michael Overesch, 2017. "Multinationals profit response to tax differentials: Effect size and shifting channels," Canadian Journal of Economics, Canadian Economics Association, vol. 50(4), pages 965-994, November.
    26. Wier, Ludvig, 2020. "Tax-motivated transfer mispricing in South Africa: Direct evidence using transaction data," Journal of Public Economics, Elsevier, vol. 184(C).
    27. Dischinger, Matthias & Riedel, Nadine, 2011. "Corporate taxes and the location of intangible assets within multinational firms," Journal of Public Economics, Elsevier, vol. 95(7), pages 691-707.
    28. Slemrod, Joel, 2004. "Are corporate tax rates, or countries, converging?," Journal of Public Economics, Elsevier, vol. 88(6), pages 1169-1186, June.
    29. Dhammika Dharmapala, 2018. "The Consequences of the TCJA's International Provisions: Lessons from Existing Research," CESifo Working Paper Series 7249, CESifo.
    30. Hines, James R. Jr., 1999. "Lessons from Behavioral Responses to International Taxation," National Tax Journal, National Tax Association, vol. 52(n. 2), pages 305-22, June.
    31. Hines, James R. (ed.), 2001. "International Taxation and Multinational Activity," National Bureau of Economic Research Books, University of Chicago Press, edition 1, number 9780226341736, December.
    32. Matthias Dischinger & Bodo Knoll & Nadine Riedel, 2014. "The role of headquarters in multinational profit shifting strategies," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 21(2), pages 248-271, April.
    33. Bodo Knoll & Nadine Riedel, 2015. "Transfer Pricing Laws," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(04), pages 22-26, January.
    34. Luca Barbone & Richard Bird & Jaime Vázquez Caro, 2012. "The Costs of VAT: A Review of the Literature," CASE Network Reports 0106, CASE-Center for Social and Economic Research.
    35. Jost H. Heckemeyer & Michael Overesch, 2017. "Multinationals’ profit response to tax differentials: Effect size and shifting channels," Canadian Journal of Economics/Revue canadienne d'économique, John Wiley & Sons, vol. 50(4), pages 965-994, November.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Makoto HASEGAWA & Michi KAKEBAYASHI, 2023. "The Effect of Foreign Dividend Exemption on Profit Repatriation through Dividends, Royalties, and Interest: Evidence from Japan," Discussion papers e-20-004, Graduate School of Economics , Kyoto University.
    2. Tomomi Sakurai, 2020. "Profit Shifting by Japanese Multinational Corporations," Discussion papers ron332, Policy Research Institute, Ministry of Finance Japan.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Sebastian Beer & Ruud de Mooij & Li Liu, 2020. "International Corporate Tax Avoidance: A Review Of The Channels, Magnitudes, And Blind Spots," Journal of Economic Surveys, Wiley Blackwell, vol. 34(3), pages 660-688, July.
    2. Langenmayr, Dominika & Liu, Li, 2023. "Home or away? Profit shifting with territorial taxation," Journal of Public Economics, Elsevier, vol. 217(C).
    3. Garcia-Bernardo, Javier & Janský, Petr, 2024. "Profit shifting of multinational corporations worldwide," World Development, Elsevier, vol. 177(C).
    4. Ludvig Wier & Hayley Erasmus, 2023. "The Dominant Role of Large Firms in Profit Shifting," IMF Economic Review, Palgrave Macmillan;International Monetary Fund, vol. 71(3), pages 791-816, September.
    5. Ropponen, Olli, 2021. "Interest Limitation Rules and Business Cycles: Empirical Evidence," ETLA Working Papers 90, The Research Institute of the Finnish Economy.
    6. Sabine Schenkelberg, 2020. "The Cadbury Schweppes judgment and its implications on profit shifting activities within Europe," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 27(1), pages 1-31, February.
    7. Cooper, Maggie & Nguyen, Quyen T.K., 2020. "Multinational enterprises and corporate tax planning: A review of literature and suggestions for a future research agenda," International Business Review, Elsevier, vol. 29(3).
    8. Bakke, Julia Tropina & Hopland, Arnt Ove & Møen, Jarle, 2019. "Profit shifting and the effect of stricter transfer pricing regulation on tax revenue," Discussion Papers 2019/11, Norwegian School of Economics, Department of Business and Management Science.
    9. Ruud Mooij & Li Liu, 2020. "At a Cost: The Real Effects of Transfer Pricing Regulations," IMF Economic Review, Palgrave Macmillan;International Monetary Fund, vol. 68(1), pages 268-306, March.
    10. Fuest, Clemens & Hugger, Felix & Neumeier, Florian, 2022. "Corporate profit shifting and the role of tax havens: Evidence from German country-by-country reporting data," Journal of Economic Behavior & Organization, Elsevier, vol. 194(C), pages 454-477.
    11. Dominika Langenmayr & Franz Reiter, 2022. "Trading offshore: evidence on banks’ tax avoidance," Scandinavian Journal of Economics, Wiley Blackwell, vol. 124(3), pages 797-837, July.
    12. Müller, Raphael & Spengel, Christoph & Vay, Heiko, 2020. "On the determinants and effects of corporate tax transparency: Review of an emerging literature," ZEW Discussion Papers 20-063, ZEW - Leibniz Centre for European Economic Research.
    13. Li Liu & Tim Schmidt-Eisenlohr & Dongxian Guo, 2020. "International Transfer Pricing and Tax Avoidance: Evidence from Linked Trade-Tax Statistics in the United Kingdom," The Review of Economics and Statistics, MIT Press, vol. 102(4), pages 766-778, October.
    14. Marika Viertola, 2023. "Profit Shifting of Multinational Enterprises: Evidence from the Nordics," Working Papers 18, Finnish Centre of Excellence in Tax Systems Research.
    15. Jost H. Heckemeyer & Michael Overesch, 2017. "Multinationals’ profit response to tax differentials: Effect size and shifting channels," Canadian Journal of Economics/Revue canadienne d'économique, John Wiley & Sons, vol. 50(4), pages 965-994, November.
    16. Langenmayr, Dominika & Liu, Li, 2020. "Where Does Multinational Profit Go with Territorial Taxation? Evidence from the UK," VfS Annual Conference 2020 (Virtual Conference): Gender Economics 224516, Verein für Socialpolitik / German Economic Association.
    17. Viertola, Marika, 2023. "Profit shifting of multinational enterprises: evidence from the Nordics," Working Papers 155, VATT Institute for Economic Research.
    18. Tomomi Sakurai, 2020. "Profit Shifting by Japanese Multinational Corporations," Discussion papers ron332, Policy Research Institute, Ministry of Finance Japan.
    19. Riedel Nadine, 2018. "Quantifying International Tax Avoidance: A Review of the Academic Literature," Review of Economics, De Gruyter, vol. 69(2), pages 169-181, August.
    20. Nerudova, Danuse & Dobranschi, Marian & Solilová, Veronika & Litzman, Marek, 2023. "Onshore and offshore profit shifting and tax revenue losses in the European Union," Economic Modelling, Elsevier, vol. 119(C).

    More about this item

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:ucp:nattax:doi:10.1086/727012. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Journals Division (email available below). General contact details of provider: https://www.journals.uchicago.edu/NTJ .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.