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Consequences of the New UK Tax Exemption System: Evidence from Micro‐level Data

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  • Peter Egger
  • Valeria Merlo
  • Martin Ruf
  • Georg Wamser

Abstract

Until 2009, the United Kingdom operated a system of worldwide taxation. Taxation of foreign income was deferred until repatriated as dividends, leaving UK-owned multinational firms the possibility of avoiding UK taxation by delaying dividend payments and keeping earnings abroad. In 2009, the UK switched to a system under which all foreign-earned income is exempted from taxation. This fundamental change had a number of straightforward implications for UK-owned multinational firms and particularly changed incentives to repatriate profits. This paper assesses the effects of the reform on the foreign affiliates of UK-owned multinational firms. We use data provided by Bureau van Dijk on 61,738 foreign affiliates located in one of 29 European countries to estimate the impact of the reform on the repatriation pattern and other outcomes of UK-owned affiliates. We use an identification approach that quasi-randomizes over the country of residence of the ultimate firm owners, allowing us to compare outcomes of treated UK-owned foreign affiliates to control non-UK-owned foreign affiliates. Our results suggest that the switch to tax exemption not only changed dividend repatriation behavior of firms but also the conditions under which foreign entities operate in general, for instance, with regard to investment behavior.
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  • Peter Egger & Valeria Merlo & Martin Ruf & Georg Wamser, 2015. "Consequences of the New UK Tax Exemption System: Evidence from Micro‐level Data," Economic Journal, Royal Economic Society, vol. 125(589), pages 1764-1789, December.
  • Handle: RePEc:wly:econjl:v:125:y:2015:i:589:p:1764-1789
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    File URL: http://hdl.handle.net/10.1111/ecoj.2015.125.issue-589
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    Cited by:

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    2. Dong, Qi Flora & Cao, Yiting & Zhao, Xin & Deshmukh, Ashutosh, 2019. "Responses of US multinational firms to a temporary repatriation tax holiday: A literature review and synthesis," Journal of Accounting Literature, Elsevier, vol. 43(C), pages 108-123.
    3. Bilicka, Katarzyna & Qi, Yaxuan & Xing, Jing, 2022. "Real responses to anti-tax avoidance: Evidence from the UK Worldwide Debt Cap," Journal of Public Economics, Elsevier, vol. 214(C).
    4. Goldbach, Stefan & Nagengast, Arne J. & Steinmüller, Elias & Wamser, Georg, 2019. "The effect of investing abroad on investment at home: On the role of technology, tax savings, and internal capital markets," Journal of International Economics, Elsevier, vol. 116(C), pages 58-73.
    5. 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.
    6. 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.
    7. Dominika Langenmayr & Li Liu, 2020. "Where Does Multinational Profit Go with Territorial Taxation? Evidence from the UK," CESifo Working Paper Series 8047, CESifo.
    8. 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.
    9. Azémar, Céline & Dharmapala, Dhammika, 2019. "Tax sparing agreements, territorial tax reforms, and foreign direct investment," Journal of Public Economics, Elsevier, vol. 169(C), pages 89-108.
    10. 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.
    11. Overesch Michael, 2016. "Steuervermeidung multinationaler Unternehmen," Perspektiven der Wirtschaftspolitik, De Gruyter, vol. 17(2), pages 129-143, July.
    12. Muhammad Tahir & Haslindar Ibrahim & Abdul Hadi Zulkafli & Muhammad Mushtaq, 2020. "Influence of Exchange Rate Fluctuations and Credit Supply on Dividend Repatriation Policy of U.S. Multinational Corporations," Journal of Central Banking Theory and Practice, Central bank of Montenegro, vol. 9(special i), pages 267-290.
    13. Jozef Konings & Catherine Lecocq & Bruno Merlevede, 2022. "Does a tax deduction scheme matter for jobs and investment by multinational and domestic enterprises?," Canadian Journal of Economics/Revue canadienne d'économique, John Wiley & Sons, vol. 55(4), pages 1966-1989, November.
    14. Céline Azémar & Dhammika Dharmapala, 2016. "Tax Sparing, FDI, and Foreign Aid: Evidence from Territorial Tax Reforms," CESifo Working Paper Series 5874, CESifo.
    15. Michael Overesch & Sabine Schenkelberg & Georg Wamser, 2018. "Do US Firms Pay Less Tax than their European Peers? On Firm Characteristics, Profit Shifting Opportunities, and Tax Legislation as Determinants of Tax Differentials," CESifo Working Paper Series 6960, CESifo.
    16. Peter Egger & Michael Stimmelmayr, 2017. "Taxation and the Multinational Firm," CESifo Working Paper Series 6384, CESifo.
    17. Konings, Jozef & Lecocq, Cathy & Merlevede, Bruno, 2018. "Does a Tax Credit matter for Job Creation by Multinational Enterprises?," CEPR Discussion Papers 13105, C.E.P.R. Discussion Papers.
    18. M. Jonathan C. Eklund, 2022. "Do multinational firms respond to personal dividend income tax rates?," Empirical Economics, Springer, vol. 62(4), pages 1743-1771, April.
    19. Holzmann, Carolin & Büttner, Thiess, 2018. "Switching to Territorial Taxation: FDI Effects for Host-Countries of Foreign Subsidiaries," VfS Annual Conference 2018 (Freiburg, Breisgau): Digital Economy 181555, Verein für Socialpolitik / German Economic Association.
    20. Katarzyna Bilicka, 2021. "Labor Market Consequences of Antitax Avoidance Policies," Upjohn Working Papers 21-354, W.E. Upjohn Institute for Employment Research.
    21. Harendt, Christoph & Dreßler, Daniel & Overesch, Michael, 2016. "The Impact of Tax Treaties and Repatriation Taxes on FDI Revisited," VfS Annual Conference 2016 (Augsburg): Demographic Change 145588, Verein für Socialpolitik / German Economic Association.
    22. Dongxian Guo & Li Liu & Tim Schmidt-Eisenlohr, 2017. "International Transfer Pricing and Tax Avoidance : Evidence from Linked Trade-Tax Statistics in the UK," International Finance Discussion Papers 1214, Board of Governors of the Federal Reserve System (U.S.).
    23. Ms. Li Liu, 2018. "Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK," IMF Working Papers 2018/007, International Monetary Fund.

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    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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