Hold or sell? How capital gains taxation affects holding decisions

Investments with exit flexibility require decisions regarding both the investment and holding period. Because selling an investment often leads to taxable capital gains, which crucially depend on the duration of an investment, we investigate the impact of capital gains taxation on exit timing under different tax systems. We observed that capital gains taxation delays exit decisions but loses its decision relevance for very long holdings. Often the optimal exit time, which indicates the maximal present value of future cashflows, cannot be determined analytically. However, we identify the breakeven exit time that guarantees present values exceeding those of an immediate sale. While, after-taxes, an immediate sale is often optimal, long holding periods might also be attractive for investors depending on the degree of income and corporate tax integration. A classic corporate tax system often indicates holdings over more than 100 periods. By contrast, a shareholder relief system indicates the earliest breakeven exit time and thus the highest level of exit timing flexibility. Surprisingly, high retention rates are likely to accelerate sales under a classic corporate system. Additionally, the worst exit time, which should be avoided by investors, differs tremendously across tax systems. For an integrated tax system with full imputation, the worst time is reached earlier than under partial or non-integrated systems. These results could help to predict investors’ behavior regarding changes in capital gains taxation and thus are of interest for both investors and tax policymakers. Furthermore, the results emphasize the need to control for the underlying tax system in cross-country empirical studies.     

Der Einfluss der Zinsschranke auf unternehmerische Kapitalstrukturentscheidungen

In principle corporations are free to raise debt capital or equity capital. To protect tax revenues and to increase corporations?? equity ratio Germany has introduced an interest ceiling rule. From a tax planer??s point of view it is not clear whether debt or equity capital is advantageous. On the basis of Miller (J Finance 32:261?C275, 1977) we analyze whether this interest ceiling rule discriminates debt capital against equity capital. We find that investors can be indifferent towards the capital structure with and without considering the interest ceiling rule. This result does not depend on the investors?? percentage of participation or the corporation??s optimal dividend policy. The result depends significantly on the profit, the deductible fraction of EBITDA, the tax rates and when capital gains are realized. The advantage of debt capital normally decreases due to the introduction of this regulation but in some cases even increases. Nevertheless, many investors will prefer debt capital even when the interest ceiling rule applies. This result also arises in the case of external debt financing. Thus, it is an open question whether this regulation leads to higher equity ratios.     

Die Entscheidung über den Verkauf von Wertpapieren unter der Abgeltungssteuer und auf Basis subjektiver Erwartungen

Since January 1, 2009 realized capital gains on securities are taxable in Germany regardless of the investor’s holding period. This paper examines when a rational investor should optimally sell a security in the presence of capital gains taxes. Besides taxes, our analysis considers the relevance of investor’s subjective expectations about future market prices of the security. The results suggest that investors should base divestment decisions primarily on their expectations. To realize losses or to avoid the realization of taxable gains (i.e. the lock-in-effect) is of minor importance for the optimal divestment strategy. This result becomes even more pronounced when transaction costs and limitations to save taxes by realizing losses are considered. Numerical calculations illustrate the results of our analysis.     

Welche privaten Veräußerungsgewinne sollten besteuert werden?

This paper analyses for various corporate tax systems whether the capital gains tax distorts investment decisions and how tax effects could eventually be neutralized. In case of the disposal of shares between private investors the capital gains tax, the corporate tax and the income tax on dividends induce a triple taxation. On the contrary, distributing cash via share repurchases instead of paying out dividends can lower the tax burden in a classical corporate tax system and a shareholder relief system respectively. These findings necessitate the differentiation between share repurchases and other realizations of stocks in order to establish a neutral capital gains tax. While the capital gains taxation on transactions between private investors has to be reduced, the taxation of share repurchases must be matched with the respective dividend taxation.     

Tax attractiveness and the location of German-controlled subsidiaries

This paper analyzes whether taxation has an influence on the location decisions of multinational enterprises. We employ a novel set of 22 tax variables, such as the taxation of dividends and capital gains, withholding taxes, the existence of a group taxation regime, and thin capitalization rules. Furthermore, we use the Tax Attractiveness Index, a new aggregate measure containing the 22 tax variables. Our count data regression analysis is based on a novel hand-collected dataset consisting of the subsidiaries of German DAX30 companies in 97 countries. Controlling for non-tax effects, we find that a country’s tax environment has a significantly positive effect on the number of German-controlled subsidiaries and, therefore, on the location decisions of German multinational enterprises. Specifically, our analysis reveals that German multinational firms place affiliates in countries that offer favorable statutory tax rates, withholding taxes, double tax treaty networks, and holding incentives. Additionally, we find that the Tax Attractiveness Index has explanatory power in subsidiary location decisions and, therefore, it can be used as alternative composite measure, for example, when 22 single tax variables are not at disposal.     

The impact of tax uncertainty on irreversible investment

Traditional models of capital budgeting with taxes are based on deterministic tax rates and tax bases. In reality, however, there are multiple sources of tax uncertainty. Frequent tax reforms make future taxation of investments a stochastic process. Fiscal authorities and tax courts create additional tax uncertainty by interpreting current tax laws differently. Moreover, simplified models that anticipate the actual tax base incorrectly contribute to tax uncertainty as perceived by investors. I analyze the effects of stochastic taxation on investment behavior in a real options model. The investor holds an option to invest in an irreversible project with stochastic cash flows and stochastic tax payments. Pre-tax cash flows and tax payments are assumed to be correlated. Increased tax uncertainty has an ambiguous impact on investment timing. For low tax uncertainty, high cash flow uncertainty and high correlation of cash flows and tax payments, increased tax uncertainty is likely to accelerate investment. A higher expected tax payment delays investment. A higher after-tax discount rate affects investment timing ambiguously.     

Taxes,risky investments,and the simultaneous choice of organizational form and financing

By taking explicit account of liability limitations, we analyse the influence of taxes on the simultaneous choice of organizational form and financing. In a two-state model for a single reporting period investors striving for maximisation of expected utility choose the organizational form (with or without liability limitation) in which they implement a given risky real investment and decide how they finance it (equity or debt). We demonstrate that liability limitations result in tax-relevant differences between organizational forms. Thus, for example, the tax bases differ in relation to the chosen liability-contingent debt capital compensations as well as to tax loss offset rules. Therefore, even in the event of identical tax rates, taxes can influence the decision regarding the organizational form.     

Zur Zeitwertbilanzierung latenter Steuern in der internationalen Rechnungslegung

The significance of deferred taxes was increased by the introduction of international financial reporting standards. However, the usefulness of the information provided by interperiod tax allocation is regarded with skepticism by researchers and practitioners alike. This is largely due to the overestimation of the book value of non-current deferred tax liabilities and deferred tax assets as the present value of these items is disregarded. The IASB refuses to discount deferred taxes even though this would comply with the underlying asset-liability-concept. The IASB justifies the ban on discounting deferred taxes by the ??supposed?? high complexity; hence, cost-benefit considerations. The paper at hand analyses critical issues regarding the determination of the present value of deferred taxes. An approach for determining the maturity of deferred taxes, a risk-adequate discount rate and an approach for the derivation of a feasible net present value calculation are proposed. It is shown that discounting of deferred taxes is generally possible without resulting in more complex estimations than in those of other accounting areas. Despite the inevitable discretion management has in estimating the present value, it is still possible to represent such information faithfully so that the relevant information is useful to external users.     

Financing Unemployment Benefits: Dismissal versus Employment Taxes

Abstract. This paper investigates the effects of using dismissal taxes to finance unemployment benefits. We compare dismissal and employment taxes in a model with search frictions. Employment taxes give rise to externalities because firms do not take into account the effects their dismissal decisions have on others. These externalities can be tackled by using dismissal taxes to finance unemployment insurance. Taking into account the budget for unemployment insurance, employment taxes can be reduced by more than is necessary to offset the adverse effect of dismissal taxes on the value of the firm. The introduction of dismissal taxes leads to higher job creation and lower unemployment.     

A POLITICAL ECONOMY THEORY OF PARTIAL DECENTRALIZATION

We revisit the classic problem of tax competition in the context of federal nations, and derive a positive theory of partial decentralization. A capital poor median voter chooses to use redistributive capital taxes to provide public goods. The expectation of high capital taxes, however, results in a small capital stock which lowers returns to redistribution. The median voter therefore wants to commit to a lower level of capital taxes. She does so by setting a partial degree of decentralization in the Constitution. The equilibrium degree of decentralization balances the positive effect of tax competition on capital taxes with the loss in redistribution that results. We show that the degree of decentralization is nonmonotonic in inequality, increasing in the redistributive efficiency of public good provision, and decreasing in capital productivity. When public goods are heterogeneous in their capacity to transfer funds, all voters agree that goods with high redistributive capacity should be decentralized.     

Forschungsziele der Betriebswirtschaftlichen Steuerlehre in der Kritik

In this article the understanding of the scientific functions of business taxation represented by Jochen Hundsdoerfer, Dirk Kiesewetter and Caren Sureth is critically analyzed. It is argued that hypotheses on the influence of taxes on decisions, as far as they are based on neoclassical models, are not applicable to explain the actions of tax payers. These arguments at the same time object the realization of a neutral tax system. They further contradict the realization of a tax system, which is supposed to have an impact or which avoids taxes to have an effect on decisions, provided that the criticized hypotheses are used as a basis. Fiscal law standards should rather fulfil the principle of equability of taxation. It is supposed that such fiscal law standards have an effect on decisions of tax payers, which are contradictory to the aim of an equable taxation. Therefore hypotheses from scientific experience of the actual effect of taxes on decisions must be taken into account. Hence the object of this analysis is to investigate the real influence of taxes on decisions detached from neo-classical models.     

Unternehmensbewertung bei wertabhängiger und autonomer Finanzierungspolitik unter Berücksichtigung einer Kursgewinnbesteuerung

The German tax reform in 2009 entails the general taxation of realized capital gains. The objective of this paper is to investigate the effect of a differentiated taxation of dividend payments and capital gains on discounted cash flow valuations. We develop explicit und practical useful valuation formulas for the free cash flow approach in case of financing based on market values and the adjusted present value approach in case of autonomous financing. Furthermore it is shown how the required risk-adjusted cost of equity can be derived from a modified Tax-CAPM. Finally we discuss how the particularities resulting from the new German tax law can be taken into account in discounted cash flow valuations.     

投资者的博彩行为研究——基于盈亏状态和投资者情绪的视角

本文以中国股市2000年1月至2017年9月的数据为样本，实证研究盈亏状态和投资者情绪对股票市场博彩行为的影响。本文首先构造股票博彩指数和资本利得量以及二者的交互项，然后使用Fama-MacBeth回归并分析该交互项系数估计量的统计显著性和经济显著性，结果发现，尽管我国股市投资者总体上表现出博彩偏好，但当投资者处于盈利状态时，投资者会厌恶风险，不愿意冒险买入或继续持有"博彩型"股。本文还构造了投资者情绪指数，并以中位数为界将全样本分为投资者情绪高涨期和低落期，然后通过分组研究发现，投资者情绪对博彩行为有直接和间接两种影响：较之于情绪低落期，投资者在情绪高涨期会更加偏好投资"博彩型"股票；此外，情绪还会通过影响投资者的风险态度进而间接影响投资者对"博彩型"股票的投资决策。     

对企业实行债转股的思考

启动财务杠杆给企业带来的效益一直是理论界关注的焦点.本文所介绍的是在西方较为流行的两种对启动财务杠杆实行馈转股的企业进行效益分析的理论模型.第—种模型强调资本成本在债转股中的重要性,认为企业制订是否实行债转股的决策依据就是对企业破产成本,委托代理成本和无形资产成本的评估.而对投资者来说,在投资中选择持债还是持股也依据他们对委托代理成本和无形资产的评估.第二种模型则建议企业在启动资本杠杆实行债转股中注重对风险的规避. 对于中国国有企业实行的债转股,本文以为它在所有制、市场条件及社会经济制度背景等方面具有完全不同的性质.但我们仍可以利用财务杠杆的工作原理将国有企业的债务转为股份公开上市交易,以实行中国国有企业的民营化,减轻企业的债务负担,同时减少国有银行的呆坏帐.     

Taxes and the choice between risky and risk-free debt: on the neutrality of credit default taxation

Shareholders can decide if their corporation issues risky or risk-free debt. We identify tax systems in which the choice between risky and risk-free debt is not distorted by taxes. These credit default neutral tax systems make it possible to make capital structure decisions and firm valuations neglecting credit default risk, even after taxes. Thus credit default neutrality is a characteristic of a tax system that helps to reduce planning costs. Moreover, credit default neutrality is a necessary condition for financial neutrality of taxation. We find one class of credit default neutral taxes that preserves and another class that modifies the expected tax distribution between creditors and debtor firm. Finally, we show the influence of personal taxation on credit default neutrality.

Steuerfreiheit von Gewinnen aus der Ver?u?erung von Kapitalgesellschaftsanteilen durch nat��rliche Personen?

Subject of this article is the question for the taxation of capital gains of holdings in corporations, in which tax effects are reduced. Thereby tax effects are explicated under realistic uncertainty. Under realistic uncertainty tax effects are possible in case of taxation of capital gains, but not mandatory. Furthermore the analysis shows that for capital gains from concealed reserves each form of taxation will entail tax effects. This also applies to tax exemption. In the case of capital gains from profit reserves in the applicable corporate income tax system, tax exemption of capital gains from profit reserves and immediate write-off of profit reserves itself evoke tax effects. In the current corporate tax system only the distribution induced write-down of a shareholding to going concern value reduces tax effects. Nevertheless, this only applies to personal corporations, for public corporations tax effects have to be accepted. Beyond the valid tax system, tax effects must also be expected in a tax system, in which the corporate tax is integrated in the income tax and in which capital gains from profit reserves are tax-exempt. In comparison, the Dual Income Tax as proposed by the German Council of Economic Experts is a better solution for the problem of tax effects caused by the tax exemption of capital gains.     

Modellierung von Aktienanlagen bei laufenden Umschichtungen und einer Besteuerung von Veräußerungsgewinnen

This paper develops a technique which simplifies the calculation of terminal values of share investments when portfolio turnovers repeatedly trigger capital gains taxation. So far, the calculations of these values are difficult, due to recursive dependencies, which cannot be expressed by geometric series. Using our technique, tax burdens of differently taxed forms of share investments can be determined in an easy way even if these methods imply different elements of deferred taxation (equity funds, certificates, preferred taxed pension plans). The simplification is reached by assuming a specific trading strategy. This strategy is in line with empirically observed investor behavior which is characterized by periodical portfolio turnovers and reluctance to realize taxable capital gains.     

Latente Steuern und Earnings Management

On the one hand deferred income taxes can be used for earnings management for external reporting purposes by itself. On the other hand deferred income taxes can indicate earnings management in other accounting areas, fraud and aggressive tax management. Empirical research was able to identify the usefulness of information provided by sundry components of the reported income tax expense for users of financial statements. In particular, the German literature concerning financial statement analysis underestimates the value of this information. This paper critically reviews empirical research and draws conclusions for financial statement analysis and for future studies in this area.     

基于参数模拟的中国物业税调控能力研究

通过构建包含投机型消费者、自住型消费者以及房地产商在内的住宅市场税收影响模型,利用数值模拟的估计方法,分析比较开征物业税与现存流转税对消费者和房地产商决策行为的影响,表明物业税和流转税对均衡房价的影响及其程度,用以探讨物业税对中国市场的调控能力.研究发现:1)物业税相对于其他税种,调控作用更为明显,对参与者决策行为有更...     

Income determination for corporate tax purposes using IFRS as a starting point: evidence for listed companies within Austria, Germany, and The Netherlands

The internationalisation of financial accounting and the European Commission’s ambition to harmonise corporate taxation have raised the question whether IFRS accounts could be used for tax purposes. In order to quantify the effects of an IFRS-based taxation on corporate tax burdens in different EU member states, we estimate firms’ tax equity using notes on income taxes in IFRS financial statements of companies listed in Austria, Germany, and The Netherlands. The difference between estimated tax equity and IFRS-equity, adjusted for the effect resulting from the recognition of deferred taxes, shows the effect of using IFRS as a tax base on the present value of corporate taxes. We find that estimated tax equity is mostly lower than IFRS-equity, indicating that an IFRS-based taxation would often increase the present value of corporate taxes. The median of estimated tax equity is 5.6 % (Austria), 6.4 % (Germany) and 9.0 % (The Netherlands) below IFRS-equity. However, an IFRS-based taxation does not always induce higher equity as often argued in the literature. In 307 of 1,113 totally analysed firm-years, estimated tax equity exceeds IFRS-equity. To find a further estimation for the effects of tax base reforms we also approximate the total stock of unused tax losses and the amount of useable tax losses. We find that deferred tax assets for unused tax losses are depreciated to a substantial extent.