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Intercompany Loans and Profit Shifting – Evidence from Company-Level Data

Author

Listed:
  • Thiess Büttner
  • Georg Wamser
Abstract
This paper is concerned with tax-planning strategies of multinational corporations. A theoretical analysis discusses the choice of the capital structure in a setting where intercompany loans can be used to shift profits to low-tax countries. Empirical evidence is provided using micro-level panel data of virtually all German multinationals made available by the Bundesbank. This comprehensive dataset allows us to exploit differences in taxing conditions of almost eighty countries during a period of nine years. The empirical results confirm a robust impact of tax-rate differences within the multinational group on the use of intercompany loans, supporting the profit-shifting hypothesis. However, the implied tax-revenue effects are rather small, suggesting that costs related to adjusting the capital structure for profit-shifting purposes are substantial.

Suggested Citation

  • Thiess Büttner & Georg Wamser, 2007. "Intercompany Loans and Profit Shifting – Evidence from Company-Level Data," CESifo Working Paper Series 1959, CESifo.
    • Handle: RePEc:ces:ceswps:_1959
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    References listed on IDEAS

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    14. repec:bla:jfinan:v:59:y:2004:i:6:p:2451-2487 is not listed on IDEAS
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    Full references (including those not matched with items on IDEAS)

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    Cited by:

    1. Dharmapala, Dhammika & Riedel, Nadine, 2013. "Earnings shocks and tax-motivated income-shifting: Evidence from European multinationals," Journal of Public Economics, Elsevier, vol. 97(C), pages 95-107.
    2. Amegashie, J. Atsu & Ouattara, Bazoumanna & Strobl, Eric, 2007. "Moral Hazard and the Composition of Transfers: Theory with an Application to Foreign Aid," MPRA Paper 3158, University Library of Munich, Germany, revised 06 May 2007.
    3. An, Zhiyong & Tan, Congyan, 2014. "Taxation and income shifting: Empirical evidence from a quasi-experiment in China," Economic Systems, Elsevier, vol. 38(4), pages 588-596.
    4. Gumpert, Anna & Hines, James R. & Schnitzer, Monika, 2011. "The use of tax havens in exemption regimes," Discussion Paper Series 1: Economic Studies 2011,30, Deutsche Bundesbank.
    5. Francesca Barion & Raffaele Miniaci & Paolo Panteghini & Maria Laura Parisi, 2010. "Profit Shifting by Debt Financing in Europe," CESifo Working Paper Series 2985, CESifo.
    6. Schindler, Dirk & Schjelderup, Guttorm, 2008. "Multinationals, Minority Ownership and Tax-Efficient Financing Structures," Discussion Papers 2008/19, Norwegian School of Economics, Department of Business and Management Science.
    7. Becker, Johannes & Riedel, Nadine, 2012. "Cross-border tax effects on affiliate investment—Evidence from European multinationals," European Economic Review, Elsevier, vol. 56(3), pages 436-450.
    8. Finér, Lauri & Ylönen, Matti, 2017. "Tax-driven wealth chains: A multiple case study of tax avoidance in the finnish mining sector," CRITICAL PERSPECTIVES ON ACCOUNTING, Elsevier, vol. 48(C), pages 53-81.
    9. Dischinger, Matthias & Riedel, Nadine, 2010. "The Role of Headquarters Firms in Multinational Profit Shifting Strategies," Discussion Papers in Economics 11352, University of Munich, Department of Economics.
    10. Møen, Jarle & Schindler, Dirk & Schjelderup, Guttorm, 2008. "Capital Structure and International Debt Shifting: A Comment," Discussion Papers 2008/15, Norwegian School of Economics, Department of Business and Management Science.
    11. Dirk Schindler & Guttorm Schjelderup, 2013. "Transfer Pricing and Debt Shifting in Multinationals," CESifo Working Paper Series 4381, CESifo.
    12. Ivana Durovic, 2017. "The effects of intercompany lending on the current account balances of selected economies in the Western Balkans," Public Sector Economics, Institute of Public Finance, vol. 41(4), pages 421-441.
    13. Matthias Dischinger & Nadine Riedel, 2010. "The Role of Headquarters in Multinational Profit Shifting Strategies," Working Papers 1003, Oxford University Centre for Business Taxation.
    14. Petr Janský & Ondřej Kokeš, 2015. "Corporate tax base erosion and profit shifting out of the Czech Republic," Post-Communist Economies, Taylor & Francis Journals, vol. 27(4), pages 537-546, December.
    15. Copenhagen Economics, 2011. "Elasticities of Financial Instruments, Profits and Remuneration," Taxation Papers 30, Directorate General Taxation and Customs Union, European Commission.

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    More about this item

    Keywords

    corporate taxation; multination corporations; tax planning; intercompany loans; tax haven; FDI; micro-level data;
    All these keywords.

    JEL classification:

    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • G32 - Financial Economics - - Corporate Finance and Governance - - - Financing Policy; Financial Risk and Risk Management; Capital and Ownership Structure; Value of Firms; Goodwill
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies

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