Double tax discrimination to attract FDI and fight profit shifting: The role of CFC rules

• 成果类型: Article
• 署名作者: Haufler, Andreas; Mardan, Mohammed; Schindler, Dirk
• 署名单位: University of Munich; Leibniz Association; Ifo Institut; Swiss Federal Institutes of Technology Domain; ETH Zurich; Norwegian School of Economics (NHH); Norwegian School of Economics (NHH)
• 刊物名称: JOURNAL OF INTERNATIONAL ECONOMICS
• ISSN/ISSBN: 0022-1996
• DOI: 10.1016/j.jinteco.2018.04.007
• 发表日期: 2018
• 页码: 25-43
• 关键词: MULTINATIONALS; Profit shifting; Controlled-foreign-company rules; Thin-capitalization rules

摘要

Governments worldwide use targeted tax policies to trade off the gains from increased FDI against the cost of excessive profit shifting by multinational firms. We show that nationally optimal tax systems generally incorporate both thin-capitalization rules, which tax discriminate between purely national and multinational firms, and controlled-foreign-company (CFC) rules, which discriminate between home-based and foreign-based multinationals. In the non-cooperative policy equilibrium both thin-capitalization rules and CFC rules are set more lenient than if tax policies were chosen cooperatively, implying an 'excessive' tax discrimination in favor of multinationals. We also analyze the effects of reduced transaction costs for FDI and reduced costs for debt shifting on the optimal policy mix. Our results correspond to the observed developments of anti-avoidance rules in OECD countries. (C) 2018 Elsevier B.V. All rights reserved.