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.

Corporation taxes and the debt policy of multinational firms

This paper analyzes the impact of corporate taxes on the capital structure of foreign subsidiaries of multinational firms. The empirical investigation employs a large micro-level panel dataset of German multinationals covering 31 countries over a 10-year period. A special feature of this dataset is that it allows us to distinguish between internal and external debt financing. Our results confirm a positive effect of local tax rates on both types of debt. Moreover, while adverse local credit market conditions are found to reduce external borrowing, internal debt is increasing, supporting the view that the two channels of debt finance are substitutes. Our findings suggest that internal credit markets give rise to significant advantages and enhance multinationals?? opportunities to use debt as a tax shield.     

SHAREHOLDER LIMITED LIABILITY AND MEAN-VARIANCE MODELS OF CAPITAL STRUCTURE*

This paper demonstrates that shareholder limited liability imposes a restriction on corporate borrowing and that failure to incorporate this restriction into the analysis yields the “reductio ad absurdum” argument against mean-variance models of optimal capital structure. With corporate income taxes and costless bankruptcy, the firm's value is a monotonically increasing function of debt as long as the amount of debt does not exceed the upper limit imposed by shareholder limited liability. As a result, the introduction of costly bankruptcy into the mean-variance framework is justified.     

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.     

认知偏差、债务政策选择偏好和资本结构税收效应

本文针对管理者认知偏差对其债务政策选择的影响问题进行研究,通过建立认知偏差影响下的最优资本结构决策模型,从行为金融学的角度研究了债务政策选择的税收效应,并以中国上市公司2006-2009年的数据为样本,使用多元回归分析等方法对相关结论进行了实证检验。研究表明:上市公司的债务政策受到了认知偏差的影响,即随着财务困境成本的不断增大,上市公司对其变化的敏感性不断降低;认知偏差严重时,上市公司会选择过度保守负债或过度积极负债,导致最优资本结构与税率无关;认知偏差不严重时,上市公司会选择适度负债,且负债水平与税率正相关。结论表明中国上市公司需要更为客观地评价财务困境成本,更为理性地利用负债的税收收益,尽可能避免认知偏差对企业价值的损害。     

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.     

Die Bedeutung von Steuern in der Nachhaltigkeitsberichterstattung: Eine international vergleichende empirische Analyse

Due to tax competition, high levels of national debt and promulgated tax avoidance strategies of large corporations, there is a growing interest of multiple stakeholders in taxation putting taxes on the corporate social responsibility (CSR) agenda. This study empirically examines the relevance of taxes in sustainability reports of 90 corporations listed on the Dow Jones 30, DAX 30 and FTSE 100. The findings show that 54,4?% of these corporations disclose tax information in their reports. The quality of disclosure is examined using a scoring model based on the tax-related performance indicators of theGlobal Reporting Initiative Guidelines and two standards for voluntary disclosure of tax information. In most cases, disclosure practices are of low quality. However, there are a few corporations providing high disclosure quality, especially in the UK. By analyzing the determinants of disclosure, this study demonstrates that extractive companies and companies that have been object of negative tax-related media coverage tend to disclose more information. Furthermore, corporations with higher profitability and high performance in CSR rankings rather disclose tax information.     

Warum Steuermoral? – Zur Explikation,Relevanz und Vorteilhaftigkeit von Steuermoral

The subject of this article is the explication, investigation of the relevance and the analysis of the advantages of tax morale. Tax morale is defined as the rejection of tax evasion and also as the rejection of special tax avoidance strategies. One argument in favor for tax morale is that tax payment can be interpreted as an elementary component of a fictitious social contract. In accordance with deontology ethics it can be traced back to the maxim “pacta sunt servanda”. Tax morale is relevant because tax evasion and tax avoidance strategies cannot be fully prevented by the tax law. The implementation of a social contract therefore requires a regulation for tax payment. The realization of a tax payment regulation would be simplified if tax payment would be beneficial. If economic income is accepted as an approximation of the financial utility from the social contract, the tax payment is absolutely beneficial in principle. In relation to the (immoral) non-payment of taxes, tax payment can be relatively advantageous or disadvantageous. One possible advantage is that (immoral) non-payment of taxes can result in punishment when detected. Another result of tax payment is the prevention of an impairment of the social contract.     

Bringing the cognitive revolution forward: What can team cognition contribute to our understanding of leadership?

Cognition is a central element of organizational behavior and leaders are seen as key shapers of organizational cognition. Leaders’ influence over organizations often occurs through their influence on the collectives or teams they are leading. Hence, leaders influence organizational outcomes by modeling team cognition. Despite the importance of this relationship for organizational outcomes, there is little integration currently between the leadership and team cognition literatures. To address this gap, we conduct an integrative review. First, we develop a model for leader and team influence based on organizational emergence and leadership complexity theories. Our model makes a distinction between the source of influence over cognition (leader → team, team → leader, reciprocal) and form of cognition emergence (variance reduction, variance enhancement); constraints that shape cognitions that vary in levels (within and between-level, contextual) and focus (individual, interindividual, collective); and leader behaviors (administrative, adaptive, enabling). We apply this model to review and analyze ninety-nine studies in the current literature and then discuss the limitations and future directions drawing on our findings and theoretical model. We contribute a unifying framework of leadership and team emergence that can be expanded and applied to other settings.     

Wird die Relevanz von Ertragsteuern für die Unternehmensrechnung nach rechtlichen oder ökonomischen Kriterien beurteilt?

Textbooks in the areas of Management Accounting, Finance and Valuation treat taxes very differently. Finance and Valuation increasingly consider tax effects. Management Accounting considers taxes only if they meet certain legal “cost” criteria. These criteria follow tax law rules, but not economic rules and primarily consider tax effects of the local business tax only. This view is also reflected in recent cost accounting regulations. We present evidence from a survey of managers and chambers of commerce, according to which practitioners’ views of whether the local business tax is a cost are heterogeneous. The majority of managers do not consider the local business tax as a cost and do not pass it on to customers. The chambers of commerce however still consider the local business tax as a cost.     

Self‐financing Unemployment Insurance and Bargaining Structure

Abstract. This study examines how the size of trade unions relative to the labor force impacts on the desirability of different organizational forms of self‐financing unemployment insurance (UI). For this purpose, we compare the outcome of a model with a uniform payroll tax to a model where workers pay taxes according to their systematic risk of unemployment. Our results highlight the importance of the bargaining structure for the assessment of a particular UI scheme. Most importantly, it depends on the relative size of the unions whether efficiency favors a uniform or a differentiated UI scheme.     

税率不确定性下的减记型二级资本债设计及银行最优债务结构

考虑了税率不确定下减记型二级资本债（减记债）设计和银行最优债务结构问题。假设银行的融资方式为股权,普通债和减记债,在税率不确定环境下,利用动态规划方法,解析地得到了银行证券的价值和银行最优债务结构。分析了税率不确定性对银行融资决策的影响。结论表明：普通债的最优券息是减记比例的凸函数,随着减税而减少,随着减税时间点的增加而增加。减记债最优券息随着减记比例先增后减,受减税和减税时间点的影响是不确定的。此外,银行总价值和最优杠杆率随着减记比例先增后减。本文也为我国"营改增"政策的可行性提供了理论依据。同时,从银行总价值最大化和税率效应角度为金融决策者如何灵活地选择适当的减记比例提供了理论参考。     

Kapitalmarktorientierte Unternehmensbewertung bei asymmetrischer Besteuerung von Soll- und Habenzinsen

Drukarczyk and Lobe argue that the value of a company depends on individual preferences for leveraged or unleveraged companies if debt and credit interest rates after personal taxes differ. Consequentially they derive two preference-dependent valuation formulas. Based on these results an increasing amount of literature proposing preference-dependent valuation formulas emerged. We claim that this has to be viewed critically. In order to show that even in a world of different debt and credit interest rates after personal taxes a market value can be determined we develop a new version of the Tax CAPM. Based on this model the market value of leveraged and unleveraged companies is derived. Finally we show that the corresponding valuation function significantly differs from the preference-dependent valuation formulas.     

REDISTRIBUTION,PORK, AND ELECTIONS

Why might citizens vote against redistributive policies from which they would seem to benefit? Many scholars focus on ‘wedge’ issues such as religion or race, but another explanation might be geographically‐based patronage—or pork. We examine the tension between redistribution and patronage with a model that combines partisan elections across multiple districts with legislation in spatial and divide‐the‐dollar environments. The model yields a unique equilibrium that describes the circumstances under which poor voters support right‐wing parties that favor low taxes and redistribution, and under which rich voters support left‐wing parties that favor high taxes and redistribution. The model suggests that one reason standard tax and transfer models of redistribution often do not capture empirical reality is that redistributive transfers are a less efficient tool for attracting votes than are more targeted policy programs. The model also underlines the central importance of party discipline during legislative bargaining in shaping the importance of redistribution in voter behavior, and it describes why right‐wing parties should have an advantage over left‐wing ones in majoritarian systems.     

Wird die Relevanz von Ertragsteuern für die Unternehmensrechnung nach rechtlichen oder ökonomischen Kriterien beurteilt? Kommentar zum Beitrag von Franz W. Wagner und Reinhard Sill

Wagner/Sill investigate analytically and empirically whether income taxes are integrated in cost accounting (CA) and whether the German local business tax (LBT) is different from other income taxes from a CA perspective. Using a contribution margin model, they show that neither the LBT nor other income taxes are crucial. By contrast, the empirical study reveals that businesses and industry associations perceive the LBT quite differently. The theoretical irrelevance of income taxes is a consequence of the simplified contribution margin model. Using a multi-period cost definition would induce time effects of taxation and hence the relevance of income taxes. In the empirical analysis, it is not clear what the authors mean by “integration” of taxes and which type of CA they have in mind. Since regulation is an important issue for CA, it would be helpful to distinguish between regulated and non-regulated industries in the questionnaire.     

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.     

Rotten Parents and Disciplined Children: A Politico‐Economic Theory of Public Expenditure and Debt

This paper proposes a dynamic politico‐economic theory of fiscal policy in a world comprising a set of small open economies, whose driving force is the intergenerational conflict over debt, taxes, and public goods. Subsequent generations of voters choose fiscal policy through repeated elections. The presence of young voters induces fiscal discipline, that is, low taxes and low debt accumulation. The paper characterizes the Markov‐perfect equilibrium of the voting game in each economy, as well as the stationary equilibrium debt distribution and interest rate of the world economy. The equilibrium can reproduce some salient features of fiscal policy in modern economies.     

DISTRIBUTIONAL INCENTIVES IN AN EQUILIBRIUM MODEL OF DOMESTIC SOVEREIGN DEFAULT

Europe's debt crisis resembles historical episodes of outright default on domestic public debt about which little research exists. This paper proposes a theory of domestic sovereign default based on distributional incentives affecting the welfare of risk‐averse debt and nondebtholders. A utilitarian government cannot sustain debt if default is costless. If default is costly, debt with default risk is sustainable, and debt falls as the concentration of debt ownership rises. A government favoring bond holders can also sustain debt, with debt rising as ownership becomes more concentrated. These results are robust to adding foreign investors, redistributive taxes, or a second asset.     

碳税政策下闭环供应链网络均衡分析

针对由多个制造/再制造工厂和多个需求市场构成的闭环供应链网络，考虑两种碳税政策：单一比例碳税政策和超额累进碳税政策，分别量化两种碳税政策下工厂需支付的碳税，分析两种碳税政策下闭环供应链网络各成员企业的均衡条件，建立闭环供应链网络均衡模型，提出修正投影算法求解模型，最后，通过算例，对比分析两种碳税政策对闭环供应链网络成员企业新产品产量、网络间正向/逆向产品交易量、需求、价格、减排投资、碳排放量、碳税及成员利润的影响。     

Overcoming the liability of foreignness without strong firm capabilities — the value of market-based resources

The concept of “liability of foreignness” — the costs of doing business abroad — has been known and discussed since the mid-1970s. At the core of these discussions is the role that firm capabilities play in overcoming or limiting these costs. This raises the question of how firms with inappropriate, limited or constrained capabilities relative to their host environment overcome the liability of foreignness. This paper focuses on the subsidiaries of “emerging multinationals” and how they manage the demands of a technologically and economically highly developed host country. A host location with sophisticated markets and well-developed institutional infrastructure may be a highly challenging environment for firms that have grown their organizational capabilities in less developed contexts. This paper explores that situation and considers how resources available on the market — for example through supplier inputs — assist subsidiaries to benefit from their presence in a munificent location. Despite the acknowledged limitations of a transaction-based approach, this paper presents evidence that purchasing knowledge provides an accessible strategy for overcoming some liabilities of foreignness.