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Taxation and Valuation of International Real Investments

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  • Jouko Ylä-Liedenpohja

Abstract

The study analyses the incentives for multinationals caused by linking different national tax systems. The dividend tax capitalization hypothesis is extended to include taxes during the repatriation and onward distribution (as equalization tax) to derive the relevant cost of capital formulae for each source of finance. No clear tax advantage of using debt from the parent to the foreign subsidiary is found. Tax conditions are derived for finance companies in third countries used by multinationals to park and rotate profits such as realization gains from trade sales of their subsidiaries. The same tools are applied to analyse corporate inversions.

Suggested Citation

  • Jouko Ylä-Liedenpohja, 2003. "Taxation and Valuation of International Real Investments," CESifo Working Paper Series 1013, CESifo.
    • Handle: RePEc:ces:ceswps:_1013
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    References listed on IDEAS

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    1. Weichenrieder, Alfons J., 1998. "Foreign profits and domestic investment," Journal of Public Economics, Elsevier, vol. 69(3), pages 451-463, September.
    2. Kari, Seppo & Ylä-Liedenpohja, Jouko, 2002. "Classical Corporation Tax as a Global Means of Tax Harmonization," Discussion Papers 266, VATT Institute for Economic Research.
    3. Sinn, H.W., 1990. "Taxation And The Birth Of Foreign Subsidiaries," Papers 66, Princeton, Woodrow Wilson School - Discussion Paper.
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    5. Hines, James Jr., 1994. "Credit and deferral as international investment incentives," Journal of Public Economics, Elsevier, vol. 55(2), pages 323-347, October.
    6. Liljeblom, Eva & Loflund, Anders & Hedvall, Kaj, 2001. "Foreign and domestic investors and tax induced ex-dividend day trading," Journal of Banking & Finance, Elsevier, vol. 25(9), pages 1687-1716, September.
    7. Hartman, David G., 1985. "Tax policy and foreign direct investment," Journal of Public Economics, Elsevier, vol. 26(1), pages 107-121, February.
    8. R. R. Officer, 1982. "Company Tax Systems and their Effects on Investors," The Economic Record, The Economic Society of Australia, vol. 58(4), pages 339-351, December.
    9. Sinn, Hans-Werner, 1984. "Die Bedeutung des Accelerated Cost Recovery System fur den internationalen Kapitalverkehr. (The Significance of the Accelerated Cost Recovery System for International Capital Movements. With English s," Kyklos, Wiley Blackwell, vol. 37(4), pages 542-576.
    10. Desai, Mihir A. & Hines, James R. Jr., 2002. "Expectations and Expatriations: Tracing the Causes and Consequences of Corporate Inversions," National Tax Journal, National Tax Association;National Tax Journal, vol. 55(3), pages 409-440, September.
    11. Officer, R R, 1982. "Company Tax Systems and Their Effects on Investors," The Economic Record, The Economic Society of Australia, vol. 58(163), pages 339-351, December.
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    Cited by:

    1. Seppo Kari & Jouko Ylä-Liedenpohja, 2004. "Cost of Capital for Cross-Border Investment: The Fallacy of Estonia as a Tax Haven," Baltic Journal of Economics, Baltic International Centre for Economic Policy Studies, vol. 5(1), pages 28-43, December.
    2. Rainer Niemann, 2004. "Asymmetric Taxation and Cross-Border Investment Decisions," CESifo Working Paper Series 1219, CESifo.
    3. Rainer Niemann, 2006. "Wirkungen der Abschnittsbesteuerung auf internationale Investitions- und Repatriierungsentscheidungen," Schmalenbach Journal of Business Research, Springer, vol. 58(7), pages 928-957, November.
    4. Niemann, Rainer, 2004. "Entscheidungswirkungen von Verlustverrechnungsbeschränkungen bei der Steuerplanung grenzüberschreitender Investitionen," Tübinger Diskussionsbeiträge 276, University of Tübingen, School of Business and Economics.

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    Keywords

    multinational taxation; equalization tax; profit valuation;
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