Research Phase 1        The effects of international taxation on business

1   The effects of international taxation on the activities of multinational companies: a survey of existing evidence & data sources

The Impact of Taxation on the Location of Capital, Firms and Profit: A Survey of Empirical Evidence
Michael P. Devereux
Data Appendix
Giorgia Maffini

There has been a considerable amount of economics research into the impact of taxes on multinational companies. The main issues
examined have been the impact on location choice, investment, financial policy and the location of profit. The bulk of this research has
been undertaken by US researchers, primarily using data originating from the US. Over time this work has become more sophisticated
and has used more and more detailed data.

This survey will provide a critical summary and evaluation of existing work. Two aspects are particularly important in trying to set the
scene for the new research being commissioned. First, what are the strengths and weaknesses of existing work? The survey is likely
to be critical of some existing work, particularly in the many attempts to gauge the impact of taxes on investment decisions. Second, to
what extent does existing work provide useful information about the role of taxes in Europe?

2   How are plant location decisions and capital flows in Europe affected by corporate income taxes?

Taxes and the size of the foreign-owned capital stock: which tax rates matter?
Ben Lockwood

There is a significant literature examining the determinants of flows of foreign direct investment. However, with respect to examining
the role of taxes, this literature is deficient in a number of ways. Of particular relevance here, it does not analyse the details of business
decisions, which include both discrete choices (e.g. to locate in country A or B) and continuous choices (e.g. how much investment to
undertake, conditional on having chosen the location). The measure of tax relevant for these two decisions are, in principle, different:
the first depends on an average tax rate, and the second on a marginal tax rate.

This paper will conduct a more detailed analysis of the importance of these different types of decision, and the importance of different
forms of effective tax rate. It will use data on the foreign operations of US multinational firms, aggregated within each source country.
Specifically, it will examine the role played by the two forms of taxes on the size of the capital stock owned by US multinationals in each

3   How far do differences in international tax regimes between countries affect financial policies?

Capital Structure and International Debt Shifting in Europe
Harry Huizinga

There has been surprisingly little empirical research, especially in Europe, on how differences in tax rates between countries can affect
business financial policies. Yet taxes are clearly a factor in how multinational companies determine their financial arrangements: the
statutory tax rate determines the benefit of interest deductibility, and the form of integration of corporate and personal taxes may affect
the value of dividends.

This paper would aim to develop empirical evidence of the role played by taxes; it would focus primarily on the role of differences in tax
rates on the use of debt. It would use company level data from the dataset Amadeus, which contains standardised accounting data on
a large number of companies across Europe, as well as data on their ownership. The paper would aim to consider how far differences
in the use of debt are correlated with tax rates in the countries of the subsidiary and parent, and whether the effects depend on the
taxation of outbound investment by the parent’s country.

4   Profit shifting within the EU: evidence from Germany

Profit Shifting in the EU: Evidence from Germany
Alfons Weichenreider

A large part of government policy making with respect to international taxes on business is devoted to identifying where profit is located,
and preventing excessive shifting of profits between jurisdictions. A number of recent academic papers have appeared recently which
have attempted to estimate the relationship between tax rates and the location of profit. None of these has specifically addressed the
European situation.

This paper will use detailed data, originally collected by the Bundesbank, on the activities of firms located in Germany, which includes
the ownership structure of those firms. Thus, for example, it is possible to compare rates of profit of German subsidiaries of foreign
multinational companies (further split by nationality of the parent and the existence of subsidiaries in other countries) with the rates of
profit of domestic firms.

5   Do non-profit taxes affect the location of economic activity?  Evidence from the EU

The Impact of Non-Profit Taxes on Foreign Direct Investment: Evidence from German Multinationals
Thiess Buettner

The vast majority of economics research on the impact of taxes on the behaviour of multinational firms has focused on the role of
corporate income taxes. This is for sound theoretical reasons; the basic model used in most work implies that other taxes – such as
VAT or payroll taxes – are not ultimately borne by the company, and do not affect investment or financial policy. However, a recent paper
(by Professor Jim Hines and co-authors) presented empirical evidence of an effect of “indirect” taxes on investment decisions. (In this
paper, “indirect taxes” included all non-profit taxes).

This paper would reinvestigate this question. It would go beyond the paper by Hines et al in two ways. First, it would analyse rigorously
the economic conditions under which non-income taxes might affect investment decisions. Second, it would use data on different
forms of European taxes to investigate which taxes (if any) play a role.

This paper would use the same Bundesbank data as the paper by Weichenreider. Specifically, it would examine the location of
subsidiaries of German companies to examine the role played both by profits taxes and non-profits taxes.

6   An economic analysis of ECJ judgements on corporate income taxes in the EU

Corporate Income Taxes in the EU: An Economic Assessment of the Role of the ECJ
Stephen Bond

This is the “policy paper” for the first phase of the research, and as such is rather different from the other papers. It will address two
broad issues. First, it will provide an economic analysis of the approach taken by the ECJ, and to a lesser extent, the European
Commission. To what extent is the approach (for example, to prohibit discrimination in taxation of international activities compared to
wholly domestic activities) consistent with economically-desirable features of an international tax system? And more fundamentally, is
even the continued existence of a separate accounting, source-based, tax system consistent with the ECJ’s approach? Second, given
the absence of any likelihood of a single EU-wide corporate income tax, what are the economic consequences of intermediate
possibilities, such as a common corporate income tax being agreed among a subset of EU countries?

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