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The Impact of Controlled Foreign Company Legislation on Real Investments Abroad: A Two-dimensional Regression Discontinuity Design


  • Egger, Peter
  • Wamser, Georg


Controlled foreign company (CFC) rules are frequently imposed by countries as part of their anti-tax-avoidance legislation. This paper aims at quantifying their impact on foreign investments by utilizing a regression discontinuity design and the universe of German foreign investments notified to Deutsche Bundesbank. While most regression discontinuity designs are one-dimensional, German CFC legislation gives rise to a two-dimensional design. The latter allows the local average treatment effect (LATE) to be heterogeneous along the two treatment thresholds, which are related to the level of the foreign corporate profit tax rate and to the returns on passive assets relative to total returns. We find clear evidence of a negative average LATE of the CFC legislation on the fixed assets held by German multinationals abroad. We find also evidence of some heterogeneity of LATE according to parametric as well as nonparametric estimates. On average, foreign assets are estimated to respond by about 10 million Euros in the neighborhood of the intersection of both treatment thresholds. This evidence points to a significant and economically large impact of anti-tax-avoidance legislation on multinational firms’ real activity abroad.

Suggested Citation

  • Egger, Peter & Wamser, Georg, 2011. "The Impact of Controlled Foreign Company Legislation on Real Investments Abroad: A Two-dimensional Regression Discontinuity Design," CEPR Discussion Papers 8460, C.E.P.R. Discussion Papers.
  • Handle: RePEc:cpr:ceprdp:8460

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    References listed on IDEAS

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    Cited by:

    1. Jarle Møen & Dirk Schindler & Guttorm Schjelderup & Julia Tropina, 2011. "International Debt Shifting: Do Multinationals Shift Internal or External Debt?," Working Paper Series of the Department of Economics, University of Konstanz 2011-40, Department of Economics, University of Konstanz.
    2. Sascha O. Becker & Peter H. Egger & Maximilian von Ehrlich, 2013. "Absorptive Capacity and the Growth and Investment Effects of Regional Transfers: A Regression Discontinuity Design with Heterogeneous Treatment Effects," American Economic Journal: Economic Policy, American Economic Association, vol. 5(4), pages 29-77, November.
    3. Seidel, Tobias & von Ehrlich, Maximilian, 2014. "The persistent effects of regional policy - Evidence from the West-German Zonenrandgebiet," Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100515, Verein für Socialpolitik / German Economic Association.
    4. Ruf Martin & Schindler Dirk, 2015. "Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches," Nordic Tax Journal, De Gruyter Open, vol. 2015(1), pages 17-33, September.
    5. Mardan, Mohammed & Haufler, Andreas & Schindler, Dirk, 2014. "An Economic Rationale for Controlled-Foreign-Corporation Rules," Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100405, Verein für Socialpolitik / German Economic Association.
    6. Kari Seppo, 2015. "Corporate tax in an international environment – Problems and possible remedies," Nordic Tax Journal, De Gruyter Open, vol. 2015(1), pages 1-16, September.

    More about this item


    CFC rule; Corporate profit tax; Multinational firms; Plant-level data; Regression discontinuity design; Tax avoidance;

    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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