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.     

Besteuerung multinationaler Unternehmen in der EU – eine vergleichende Analyse ausgewählter Reformvorschläge

The European Commission is currently finalizing a tax system based on a Common Consolidated Tax Base (CCCTB), which multinational corporations throughout the European Union will be able to use to determine their tax burden in accordance to this system. Besides the CCCTB, we present and analyze an alternative tax reform proposal, the European Tax Allocation System (ETAS). Our analysis is based on a dynamic capital budgeting model. The effects of the underlying European tax concepts on marginal investment of multinational groups are investigated by determining the influence of taxation on the required minimum rate of return and herewith the pre-tax cost of capital. Performing analyses for different scenarios enables us to draw more detailed conclusions about whether implementing ETAS and CCCTB can foster or discriminate real investments. Our investigation shows which tax concept and which of the analyzed parameter particularly affects the multinational’s tax burden. E.g., we find that a CCCTB can foster real investments particularly by means of retention policy and profit shifting, whereas ETAS can foster real investments effectively exploiting the Member States’ tax rate differentials and taking advantage of differing national tax regulations.     

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.     

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.     

Corporate Strategy Formulation and Taxation: Evidence from UK Firms*

This paper considers the relationship between corporate strategy formulation and taxation. Drawing on prior literature we briefly review the important influence that international taxation has on an array of corporate strategy decisions. We then consider issues in strategy formulation and taxation planning in order to develop an understanding of when and how taxation factors impinge on strategic decision‐making. We draw out the apparent paradox between the nature of strategic decision‐making and financial decision‐making and look for areas of reconciliation. In order to shed light on some of these issues we present findings from the qualitative analysis of a set of personal interviews undertaken with senior tax practitioners in seven UK‐based multinational enterprises and then consider quantitative responses from the tax practitioners working in 145 UK firms.     

Unfavorable Market Conditions,Institutional and Financial Development,and Exits of Foreign Subsidiaries

In this paper, we examine how market conditions in host countries affect the entry and exit decisions of multinational corporations' foreign subsidiaries. Taking the real options perspective, we expect that smaller investments will be associated with more flexible entries and exits. We also predict that better-established host countries with greater institutional and financial development will facilitate the exits of foreign subsidiaries with smaller investments under unfavorable market conditions. We run a Cox proportional hazard rate model with a dataset of Korean foreign direct investments, and find that when market conditions become more unfavorable, foreign subsidiaries making smaller investments that were endogenously chosen under the influence of market demand uncertainty are more likely to engage in earlier exits than subsidiaries making larger investments. We also find that strong institutional and financial development positively moderates small subsidiaries' exits under conditions of unfavorably resolved uncertainty.     

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.

Auswirkungen der deutschen Unternehmensteuerreform 2008 und der österreichischen Gruppenbesteuerung auf den grenzüberschreitenden Unternehmenserwerb

Using a simple model under certainty we show the implications of the new group relief system in Austria effective from 2005 and the reform act of business taxation 2008 in Germany on cross border marginal purchase prices and marginal seller prices concerning incorporations. The results show that the new group relief in Austria does not imply a higher marginal purchase price for a subsidiary located in Austria by an Austrian investor in comparison to his German competitor. If the German reform act of business taxation 2008 is not taken into account a German investor is able to pay higher marginal prices at the Austrian and German transaction market for companies. Considering the German tax reform act the situation changes. Now the Austrian investor is able to pay higher marginal prices for subsidiaries located in Germany and Austria.     

Conflict in foreign subsidiaries of Japanese and western multinational corporations: The impact of cultural distance and differences in home-host country combinations

This article investigates the degree of conflict between different groups of employees in MNC subsidiaries in relation to different home-host country combinations. More specifically, we compared the degree of conflict of Western subsidiaries in Japan and Japanese subsidiaries in the West. We based our comprehensive investigation on data from 617 US and German subsidiaries in Japan as well as Japanese subsidiaries in the USA and Germany (and, for comparative reasons, US subsidiaries in Germany and German subsidiaries in the US). Possibly rather surprisingly, our results indicate that different degrees of cultural distance between home and host country do not lead to different degrees of conflict in MNC subsidiaries. We suggest that expected conflicts, due to substantial cultural differences, induce employees to actively counteract such problems, leading ultimately to a reduction of real conflicts. Furthermore, while previous literature suggested that in particular Japanese subsidiaries in the West are prone to a high degree of conflicts, our findings suggest that Western subsidiaries in Japan are even more conflict-laden. This should caution Western companies against complacency when operating in Japan.     

How MNE subsidiaries transfer HRM practices in distant environments: A tale of two IKEA subsidiaries

While most research in the international business field focuses on the impact of the national institutional environment on multinational enterprises (MNEs), this paper explores the opposite relationship—the role and impact of MNE subsidiaries on the host country institutional environment. I analyze the subsidiaries' agency in the transfer activities of human resource management (HRM) practices by bringing the case of IKEA subsidiaries in Korea and Japan and find that these subsidiaries not only adapted to pressures arising from an institutional distance but also played an important role in influencing the institutional arrangement for employment system of their host countries. With a contextualized agency model, this study finds that institutional and organizational contexts that these subsidiaries are embedded in shaped their agencies and strategic responses and co-evolved with their host institutional environments while transferring HRM practices. These findings have implications for the IB and IHRM field, as they highlight the potential of MNE subsidiaries as agents.     

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.     

Payout policy,taxes, and corporate insiders: evidence from the German Tax Reduction Act 2001

Based on a large panel data set of listed German firms we analyze the corporate payout behavior around the German Tax Reduction Act 2001 (GTRA). The GTRA has considerably changed the tax preference of shareholders and consequently affected the attractiveness of different forms of payout. Using the tax reform as an exogenous source of variation we examine whether payout decisions are driven by corporate insiders or by influential shareholders. We find that the GTRA 2001 reduced both the propensity to pay dividends as well as their size. However, we find that in those firms where management board members hold substantial stakes, dividend payout behavior has not changed in the aftermath of the GTRA. This effect does not depend on the existence of other influential shareholders as for instance institutional shareholders. Hence, we conclude that the dividend policy is strongly driven by the interests of corporate insiders.     

Corporate structure optimisation for multinational companies

In this paper we consider a multinational corporate structuring problem. This problem involves designing a corporate/organisational structure (across different countries) so as to remit profits from a number of subsidiaries to a single parent company, whilst minimising the tax paid (maximise the amount received at the parent company). This corporate structure is constrained to be a (directed) tree structure.We present a mixed-integer zero-one formulation of the problem that (for the test problems examined) provides very good linear programming relaxation bounds. We also present a tabu search heuristic for the problem which, when combined with the bounds provided by the linear programming relaxation, is able to find provably optimal solutions. Extensions to the basic corporate structuring problem and how they can be dealt with using our heuristic are also discussed.Computational results for the solution (to proven optimality) of publicly available test problems involving up to 150 countries are reported. The largest problem solved previously in the literature to proven optimality involved only 22 countries.     

Die Abgeltungsteuer auf Kursgewinne und der Steuerstundungseffekt in der Unternehmensbewertung

In Germany capital gains have to be taxed independently of the holding period, according to the withholding tax regulations. Nevertheless, investors can initially avoid taxation by not realizing capital gains. Then, taxes are postponed into the future. Thereby investors can make use of an interest-free tax loan (tax deferral). Equally beneficial would be the immediate realization of negative capital gains, if this leads to reduced taxes by balancing these losses against other gains. The potential use of interest-free tax loans leads to the necessity of making assumptions on the investors?? strategy with respect to liquidation when it comes to business valuation based on discounting future after-tax payments towards investors (DCF-methods). It will be shown how much firm value depends on these assumptions by taking alternative, inflexible and flexible strategies of investors into account. Our considerations generate a lower and an upper bound for the firm value, and easier to calculate medium values. The calculations are illustrated by a numerical example which is also the subject of a comparative static analysis.     

Gleichmäßige Bewertung von Mietwohngrundstücken durch das neue steuerliche Ertragswertverfahren? Eine empirische Analyse

This paper deals with the question if the new valuation procedure for rental property established by the German Inheritance Tax Reform Act 2009 provides more consistent tax values than the previous valuation procedure which has been abolished as a result of the jurisdiction of the German Federal Constitutional Court. Our empirical findings show no improvement of the valuation results in terms of statistical spread. The only effect of the new valuation procedure is increasing tax values on average, and hence, tax values often exceed market values. But higher tax values could have been achieved with less effort by simply raising the multiplier of the previous valuation procedure. The findings of this contribution and the results of other papers suggest there is no standardised valuation procedure for rental property which provides a proper performance. Valuation of real estate remains one of the unsolved and presumably permanent problems of the inheritance tax in particular and of capital-based taxation in general.     

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.     

Gender diversity management in foreign subsidiaries: A comparative study in Germany and Japan

Gender (in)equality varies strongly across countries. However, research has not sufficiently addressed how subsidiaries of multinational companies respond to differences in gender equality between home and host countries. Based on interviews with 34 managers, our study explores how subsidiaries experience gender-related challenges in their home and host countries, what kinds of practices they implement to increase gender equality, and which role the headquarters play in the implementation of these practices. We do so by examining the cases of German subsidiaries in Japan and Japanese subsidiaries in Germany, two countries that differ greatly in gender equality. Building on our analysis, we systematically compare how subsidiaries respond to the institutional pressures from their home and host countries and develop a theoretical model that illustrates how gender diversity management in a subsidiary is contingent on the interaction of (1) global integration pressure from the headquarters and (2) the level of gender equality in the home country relative to the host country, linked via different types of collaboration and practice transfer from the headquarters. Theoretical and practical implications of our findings are discussed.     

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.     

The importance of taxes in entrepreneurial decisions: an analysis of practicing physicians’ behavior

An irrational strong importance of taxes in an individual’s decision-making behavior is one of the most popular assumptions about the behavioral effects of taxation. However, empirical research about this phenomenon is rare. In a study of German physicians, this paper analyzes whether tax aspects are over weighted in entrepreneurial decision-making. Furthermore, factors that may influence the irrational decision-making behavior of actors are analyzed. As research method, a conjoint analysis is used that permits measurement of the relative importance of tax aspects in decisions. The first result of the study is that the majority of the respondents (practicing physicians) misestimate their own marginal tax rate. The main result of the study is that––in comparison to the neoclassical model of rational maximization of consumption utility––most of the respondents overweight tax aspects. No evidence can be found for any relationship between indicators of a possible tax aversion (e.g., low satisfaction with the tax system) and attention to tax aspects in the decisions analyzed.

The international training of expatriates in Western subsidiaries of emerging multinational enterprises: A knowledge-based perspective

There is a considerable gap in academic theoretical literature about the international training of expatriates in multinational enterprises (MNEs). While the majority of research has focused on developed (Western) multinationals operating in developing countries, very limited research has been conducted on emerging multinational enterprises (EMNEs) operating in developed countries and the expatriates who work in them. In this study, we explore the international training of expatriates in Indian MNEs from the information technology industry operating in Australia to examine how they provide training to their expatriate staff who are sent on international assignments. We collected qualitative data in the form of multiple case studies via interviews with senior executives based in the Australian subsidiaries. Our findings reveal that Indian IT MNEs provide a variety of centralised training programmes for their managerial and technical expatriates and use training as a key instrument to leverage and transfer home country knowledge to their Australian subsidiaries. We also found that each stakeholder involved in the training process plays a distinct role in the knowledge transfer process, which allows Indian EMNEs to integrate the training with their people-centred business model to deliver IT services in host countries.