IDEAS home Printed from https://ideas.repec.org/p/zbw/esprep/110895.html
   My bibliography  Save this paper

Safe Haven vs. Earnings Stripping Rules: a Prisoner Dilemma?

Author

Listed:
  • Kalamov, Zarko Y.

Abstract

Internal debt financing can be used by multinational firms to shift profits from high-tax to low-tax countries. Governments apply thin capitalization rules (TCRs), which limit the deductibility of interest expenses, to restrict this behavior. TCRs fall in two main categories: safe haven rules and earnings stripping rules. We derive the locally and the socially optimal type of TCR in a general equilibrium two country model. A unilateral switch from safe haven to earnings stripping rules is welfare improving, because it allows governments to tax at different effective rates domestic and multinational firms. Thus, we provide an explanation for the recently observed trend to replace safe haven rules with earnings stripping rules. Depending on the degree of transfer price manipulation undertaken by multinational enterprises, a prisoner dilemma result emerges, as local governments may have a dominant strategy to choose earnings stripping, even when it is not mutually welfare maximizing.

Suggested Citation

  • Kalamov, Zarko Y., 2015. "Safe Haven vs. Earnings Stripping Rules: a Prisoner Dilemma?," EconStor Preprints 110895, ZBW - Leibniz Information Centre for Economics.
    • Handle: RePEc:zbw:esprep:110895
    as

    Download full text from publisher

    File URL: https://www.econstor.eu/bitstream/10419/110895/1/Safe%20Haven%20vs.%20Earnings%20stripping%20rules%20-%20a%20Prisoner%20Dilemma.pdf
    Download Restriction: no
    ---><---

    References listed on IDEAS

    as
    1. Haufler, Andreas & Schjelderup, Guttorm, 2000. "Corporate Tax Systems and Cross Country Profit Shifting," Oxford Economic Papers, Oxford University Press, vol. 52(2), pages 306-325, April.
    2. Mardan, Mohammed, 2017. "Why countries differ in thin capitalization rules: The role of financial development," European Economic Review, Elsevier, vol. 91(C), pages 1-14.
    3. Bucovetsky, Sam & Haufler, Andreas, 2008. "Tax competition when firms choose their organizational form: Should tax loopholes for multinationals be closed," Journal of International Economics, Elsevier, vol. 74(1), pages 188-201, January.
    4. Haufler, Andreas & Runkel, Marco, 2012. "Firms' financial choices and thin capitalization rules under corporate tax competition," European Economic Review, Elsevier, vol. 56(6), pages 1087-1103.
    5. Thomas Gresik & Dirk Schindler & Guttorm Schjelderup, 2015. "The Effect of Tax Havens on Host Country Welfare," CESifo Working Paper Series 5314, CESifo.
    6. Devereux, Michael P. & Lockwood, Ben & Redoano, Michela, 2008. "Do countries compete over corporate tax rates?," Journal of Public Economics, Elsevier, vol. 92(5-6), pages 1210-1235, June.
    7. Jennifer Blouin & Harry Huizinga & Luc Laeven & Gaëtan Nicodème, 2013. "Thin capitalization rules and multinational firm capital structure," Working Papers 1323, Oxford University Centre for Business Taxation.
    8. Rita de la Feria & Ana Paula Dourado, 2008. "Thin Capitalization Rules in the Context of the CCCTB," Working Papers 0804, Oxford University Centre for Business Taxation.
    9. Laurence J. Kotlikoff & Jianjun Miao, 2013. "What Does the Corporate Income Tax Tax? A Simple Model Without Capital," Annals of Economics and Finance, Society for AEF, vol. 14(1), pages 1-19, May.
    10. Dreßler, Daniel & Scheuering, Uwe, 2012. "Empirical evaluation of interest barrier effects," ZEW Discussion Papers 12-046, ZEW - Leibniz Centre for European Economic Research.
    11. Georg Wamser, 2014. "The Impact of Thin-Capitalization Rules on External Debt Usage – A Propensity Score Matching Approach," Oxford Bulletin of Economics and Statistics, Department of Economics, University of Oxford, vol. 76(5), pages 764-781, October.
    12. Alfons J. Weichenrieder & Helen Windischbauer & Alfons Weichenrieder, 2008. "Thin-Capitalization Rules and Company Responses Experience from German Legislation," CESifo Working Paper Series 2456, CESifo.
    13. Hubert Kempf & Grégoire Rota-Graziosi, 2015. "Further analysis on leadership in tax competition: the role of capital ownership—a comment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 22(6), pages 1028-1039, December.
    14. repec:ces:ifodic:v:12:y:2015:i:4:p:19151968 is not listed on IDEAS
    15. Michael Overesch & Georg Wamser, 2010. "Corporate tax planning and thin-capitalization rules: evidence from a quasi-experiment," Applied Economics, Taylor & Francis Journals, vol. 42(5), pages 563-573.
    16. Buettner, Thiess & Overesch, Michael & Schreiber, Ulrich & Wamser, Georg, 2012. "The impact of thin-capitalization rules on the capital structure of multinational firms," Journal of Public Economics, Elsevier, vol. 96(11), pages 930-938.
    17. Fuest, Clemens & Hemmelgarn, Thomas, 2005. "Corporate tax policy, foreign firm ownership and thin capitalization," Regional Science and Urban Economics, Elsevier, vol. 35(5), pages 508-526, September.
    18. Valeria Merlo & Georg Wamser, 2015. "Debt Shifting and Thin-capitalization Rules," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(04), pages 27-31, January.
    19. Valeria Merlo & Georg Wamser, 2015. "Debt Shifting and Thin-capitalization Rules," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(4), pages 27-31, 01.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Mardan, Mohammed, 2017. "Why countries differ in thin capitalization rules: The role of financial development," European Economic Review, Elsevier, vol. 91(C), pages 1-14.
    2. Gresik, Thomas A. & Schindler, Dirk & Schjelderup, Guttorm, 2017. "Immobilizing corporate income shifting: Should it be safe to strip in the harbor?," Journal of Public Economics, Elsevier, vol. 152(C), pages 68-78.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Zarko Y. Kalamov, 2020. "Safe haven or earnings stripping rules: a prisoner’s dilemma?," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 27(1), pages 38-76, February.
    2. Thiess Buettner & Michael Overesch & Georg Wamser, 2018. "Anti profit-shifting rules and foreign direct investment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 25(3), pages 553-580, June.
    3. Mardan, Mohammed, 2017. "Why countries differ in thin capitalization rules: The role of financial development," European Economic Review, Elsevier, vol. 91(C), pages 1-14.
    4. Kayis-Kumar, Ann, 2016. "What's BEPS got to do with it? Exploring the effectiveness of thin capitalisation rules," MPRA Paper 75741, University Library of Munich, Germany.
    5. Dreßler, Daniel & Scheuering, Uwe, 2012. "Empirical evaluation of interest barrier effects," ZEW Discussion Papers 12-046, ZEW - Leibniz Centre for European Economic Research.
    6. Gresik, Thomas A. & Schindler, Dirk & Schjelderup, Guttorm, 2017. "Immobilizing corporate income shifting: Should it be safe to strip in the harbor?," Journal of Public Economics, Elsevier, vol. 152(C), pages 68-78.
    7. Andreas Haufler & Mohammed Mardan & Dirk Schindler, 2016. "Optimal Policies against Profit Shifting: The Role of Controlled-Foreign-Company Rules," CESifo Working Paper Series 5850, CESifo.
    8. Haufler, Andreas & Mardan, Mohammed & Schindler, Dirk, 2018. "Double tax discrimination to attract FDI and fight profit shifting: The role of CFC rules," Journal of International Economics, Elsevier, vol. 114(C), pages 25-43.
    9. Ruf Martin & Schindler Dirk, 2015. "Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches," Nordic Tax Journal, Sciendo, vol. 2015(1), pages 17-33, September.
    10. Mardan, Mohammed & Haufler, Andreas & Schindler, Dirk, 2014. "An Economic Rationale for Controlled-Foreign-Corporation Rules," VfS Annual Conference 2014 (Hamburg): Evidence-based Economic Policy 100405, Verein für Socialpolitik / German Economic Association.
    11. Ropponen, Olli, 2021. "Interest Limitation Rules and Business Cycles: Empirical Evidence," ETLA Working Papers 90, The Research Institute of the Finnish Economy.
    12. Mongrain, Steeve & Oh, David & van Ypersele, Tanguy, 2023. "Tax competition in the presence of profit shifting," Journal of Public Economics, Elsevier, vol. 224(C).
    13. Martin Simmler, 2014. "Do multinational firms invest more? On the impact of internal debt financing on capital accumulation," Working Papers 1424, Oxford University Centre for Business Taxation.
    14. Valeria Merlo & Georg Wamser, 2015. "Debt Shifting and Thin-capitalization Rules," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(4), pages 27-31, 01.
    15. Nicolay, Katharina & Nusser, Hannah & Pfeiffer, Olena, 2017. "On the interdependency of profit shifting channels and the effectiveness of anti-avoidance legislation," ZEW Discussion Papers 17-066, ZEW - Leibniz Centre for European Economic Research.
    16. repec:ces:ifodic:v:12:y:2015:i:4:p:19151968 is not listed on IDEAS
    17. Valeria Merlo & Georg Wamser, 2015. "Debt Shifting and Thin-capitalization Rules," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(04), pages 27-31, January.
    18. Haufler, Andreas & Runkel, Marco, 2012. "Firms' financial choices and thin capitalization rules under corporate tax competition," European Economic Review, Elsevier, vol. 56(6), pages 1087-1103.
    19. Gideon Goerdt & Wolfgang Eggert, 2022. "Substitution across profit shifting methods and the impact on thin capitalization rules," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 29(3), pages 581-599, June.
    20. Thiess Buettner & Michael Overesch & Georg Wamser, 2016. "Restricted interest deductibility and multinationals’ use of internal debt finance," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 23(5), pages 785-797, October.
    21. Jarkko Harju & Ilpo Kauppinen & Olli Ropponen, 2017. "Firm Responses to an Interest Barrier: Empirical Evidence," EconPol Working Paper 3, ifo Institute - Leibniz Institute for Economic Research at the University of Munich.

    More about this item

    Keywords

    thin capitalization rules; safe haven rules; earnings stripping rules; profit shifting;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H7 - Public Economics - - State and Local Government; Intergovernmental Relations
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:zbw:esprep:110895. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: ZBW - Leibniz Information Centre for Economics (email available below). General contact details of provider: https://edirc.repec.org/data/zbwkide.html .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.