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The Effect of Moving to a Territorial Tax System on Profit Repatriation: Evidence from Japan

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  • Makoto Hasegawa

    (National Graduate Institute for Policy Studies (GRIPS))

  • Kozo Kiyota

    (Keio Economic Observatory, Keio University)

Abstract

In an increasingly globalized world, the design of international tax systems in terms of taxation on foreign corporate incomes has received much attention from policymakers and economists alike. In the past, Japan's worldwide tax system taxed foreign source income upon repatriation. However, to stimulate dividend repatriations from Japanese-owned foreign affiliates, Japan introduced a foreign dividend exemption in 2009 that exempts dividends remitted by Japanese-owned foreign affiliates to their parent firms from home taxation. This paper examines the effect of this dividend exemption on profit repatriations by Japanese multinationals. We find that the response of Japanese-owned affiliates to the dividend exemption was heterogeneous. More particularly, foreign affiliates with a large stock of retained earnings were generally more responsive to the reform and significantly increased dividend payments to their parent firms in response to the enactment of the dividend exemption system. Dividend payments by these affiliates also became more sensitive to withholding tax rates on dividends levied by host countries under the new exemption system.

Suggested Citation

  • Makoto Hasegawa & Kozo Kiyota, 2015. "The Effect of Moving to a Territorial Tax System on Profit Repatriation: Evidence from Japan," Keio-IES Discussion Paper Series 2015-008, Institute for Economics Studies, Keio University.
  • Handle: RePEc:keo:dpaper:2015-008
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    References listed on IDEAS

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    Cited by:

    1. Theresa M. Greaney & Kozo Kiyota, 2020. "Japan’s Outward FDI Potential," Working Papers 202005, University of Hawaii at Manoa, Department of Economics.
    2. Thiess Büttner & Carolin Holzmann, 2019. "Switching from Worldwide to Territorial Taxation: Empirical Evidence of FDI Effects," CESifo Working Paper Series 7462, CESifo.
    3. Dhammika Dharmapala, 2016. "The Economics of Corporate and Business Tax Reform," CESifo Working Paper Series 5864, CESifo.
    4. Dhammika Dharmapala, 2018. "The Consequences of the TCJA's International Provisions: Lessons from Existing Research," CESifo Working Paper Series 7249, CESifo.
    5. 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.
    6. Dobbelaere, Sabien & Kiyota, Kozo, 2018. "Labor market imperfections, markups and productivity in multinationals and exporters," Labour Economics, Elsevier, vol. 53(C), pages 198-212.
    7. Tetsuya Shinkai & Takao Ohkawa & Makoto Okamura & Ryoma Kitamura, 2020. "Effects of Changes in Exchange Rate Volatility on Short-run Equilibrium in International Oligopoly," Discussion Paper Series 215, School of Economics, Kwansei Gakuin University.
    8. 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.
    9. Agrawal, David R. & Mardan, Mohammed, 2019. "Will destination-based taxes be fully exploited when available? An application to the U.S. commodity tax system," Journal of Public Economics, Elsevier, vol. 169(C), pages 128-143.
    10. 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.
    11. Dominika Langenmayr & Li Liu, 2020. "Where Does Multinational Profit Go with Territorial Taxation? Evidence from the UK," CESifo Working Paper Series 8047, CESifo.
    12. 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.
    13. Bridgman, Benjamin, 2014. "Do intangible assets explain high U.S. foreign direct investment returns?," Journal of Macroeconomics, Elsevier, vol. 40(C), pages 159-171.
    14. Makoto HASEGAWA & Michi KAKEBAYASHI, 2020. "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.
    15. 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.
    16. 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.
    17. Greaney, Theresa M. & Kiyota, Kozo, 2020. "Japan's outward FDI potential," Journal of the Japanese and International Economies, Elsevier, vol. 57(C).
    18. Saskia Kohlhase & Jochen Pierk, 2020. "The effect of a worldwide tax system on tax management of foreign subsidiaries," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 51(8), pages 1312-1330, October.
    19. Peter Egger & Michael Stimmelmayr, 2017. "Taxation and the Multinational Firm," CESifo Working Paper Series 6384, CESifo.
    20. Makoto Hasegawa, 2019. "Territorial Tax Reform and Profit Shifting by US and Japanese Multinationals," KIER Working Papers 1016, Kyoto University, Institute of Economic Research.
    21. 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.
    22. Ruud A. de Mooij & Ikuo Saito, 2014. "Japan’s Corporate Income Tax; Facts, Issues and Reform Options," IMF Working Papers 14/138, International Monetary Fund.

    More about this item

    Keywords

    Local International taxation; Worldwide tax system; Territorial tax system; Profit repatriation; Dividend exemption;

    JEL classification:

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

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