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The Effect of Foreign Dividend Exemption on Profit Repatriation through Dividends, Royalties, and Interest: Evidence from Japan

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  • Makoto HASEGAWA
  • Michi KAKEBAYASHI

Abstract

Multinational corporations repatriate foreign profits through dividends, royalties, and interest paid by foreign affiliates to their parent firms. International tax rules concerning how to tax repatriated foreign earnings influence decisions on profit repatriation. In 2009, Japan introduced a foreign dividend exemption system (so-called territorial tax system) that exempted dividends received by Japanese firms from their foreign affiliates from home-country taxation. This paper examines the effects of this tax reform on profit repatriation through dividends, royalties, and interest. The enactment of the foreign dividend exemption system decreased the effective tax rate on foreign income repatriated through dividends on average by 6.8 percentage points in 2009. We find that in response to this tax rate reduction, Japanese-owned foreign affiliates increased dividend payments, but did not change either royalty or interest payments. As a result, these affiliates increased the total payments to their Japanese parents.

Suggested Citation

  • 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-v2, Graduate School of Economics , Kyoto University.
    • Handle: RePEc:kue:epaper:e-20-004-v2
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    References listed on IDEAS

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    1. 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.
    2. Dominika Langenmayr & Li Liu, 2020. "Where Does Multinational Profit Go with Territorial Taxation? Evidence from the UK," CESifo Working Paper Series 8047, CESifo.
    3. Dhammika Dharmapala, 2024. "The consequences of the 2017 US international tax reform: a survey of the evidence," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 31(4), pages 1158-1178, August.
    4. 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.
    5. Grubert, Harry, 1998. "Taxes and the division of foreign operating income among royalties, interest, dividends and retained earnings," Journal of Public Economics, Elsevier, vol. 68(2), pages 269-290, May.
    6. Barrios, Salvador & Huizinga, Harry & Laeven, Luc & Nicodème, Gaëtan, 2012. "International taxation and multinational firm location decisions," Journal of Public Economics, Elsevier, vol. 96(11), pages 946-958.
    7. Feldstein, Martin & Hines, James R. & Hubbard, R. Glenn (ed.), 1995. "The Effects of Taxation on Multinational Corporations," National Bureau of Economic Research Books, University of Chicago Press, edition 1, number 9780226240954, June.
    8. 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.
    9. Desai, Mihir A. & Foley, C. Fritz & Hines, James R. Jr., 2001. "Repatriation Taxes and Dividend Distortions," National Tax Journal, National Tax Association;National Tax Journal, vol. 54(4), pages 829-851, December.
    10. 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.
    11. Céline Azémar & Rodolphe Desbordes & Jean-Louis Mucchielli, 2007. "Do tax sparing agreements contribute to the attraction of FDI in developing countries?," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 14(5), pages 543-562, October.
    12. 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.
    13. repec:boc:pcon20:13 is not listed on IDEAS
    14. Langenmayr, Dominika & Liu, Li, 2023. "Home or away? Profit shifting with territorial taxation," Journal of Public Economics, Elsevier, vol. 217(C).
    15. 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.
    16. 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.
    17. Santos Silva, J.M.C. & Tenreyro, Silvana, 2011. "Further simulation evidence on the performance of the Poisson pseudo-maximum likelihood estimator," Economics Letters, Elsevier, vol. 112(2), pages 220-222, August.
    18. 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.
    19. Hines, James R. (ed.), 2001. "International Taxation and Multinational Activity," National Bureau of Economic Research Books, University of Chicago Press, edition 1, number 9780226341736, June.
    20. Sergio Correia & Paulo Guimarães & Tom Zylkin, 2020. "Fast Poisson estimation with high-dimensional fixed effects," Stata Journal, StataCorp LLC, vol. 20(1), pages 95-115, March.
    21. Matteo P. Arena & George W. Kutner, 2015. "Territorial Tax System Reform and Corporate Financial Policies," The Review of Financial Studies, Society for Financial Studies, vol. 28(8), pages 2250-2280.
    22. 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.
    23. 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.
    24. Martin Feldstein & James R. Hines Jr. & R. Glenn Hubbard, 1995. "The Effects of Taxation on Multinational Corporations," NBER Books, National Bureau of Economic Research, Inc, number feld95-2, October.
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    Keywords

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    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

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