We found a match
Your institution may have access to this item. Find your institution then sign in to continue.
- Title
利潤移轉的租稅誘因及反誘因對海外關係企業布局的影響- 以臺灣上市公司為例
- Authors
陳香梅; 胡偉民
- Abstract
Over the past few years, foreign investment in many countries has adopted multi-level, complex,multinational ownership control structures. InTaiwanin2015, for example, only 22.24% of overseas subsidiaries of Taiwanese listed companies were controlled by Taiwan’s parent companies, and up to 77.76% of overseas sub- sidiaries were held by intermediary affiliates. This phenomenon is often viewed by tax authorities in various countries as an arrangement for profit shifting which leads to tax base erosion. In this study, we adopt a mixed logit method, with the sample of 9,789 new subsidiaries of Taiwan’s listed companies from 2001 to 2015, located in 79 countries, to explore the influence of tax incentives relevant to profit shifting on the overseas location choice ofmultinational corporations. This project is the first to examine whether the implementation of transfer pricing or capital thinning provisions of the host country can affect the location choice of Taiwan’s subsidiaries, and it is also the first in the literature to explore the effect of bilateral tax treaties or treaty shopping on the location choice. Finally, through counterfac- tual analysis, we estimate the relative change in the probability of location choice due to relevant scenarios of tax policy changes in in various countries. Estimation results of the mean or fixed coefficients show that transfer pricing rules, capital thinning regulation and signature of a bilateral tax treaty with Taiwan are all dis- incentives for profit shifting, reducing the chances of Taiwanese listed companies establishing new subsidiaries in the country. In contrast, a tax haven or an exten- sive network of tax treaty agreements is a tax incentive for corporations to make profit transfers and increases the chances of establishing a new subsidiary. The results of counterfactual analysis predict that after the bilateral tax treatywith Tai- wan comes into effect, China will lose 29.51 percentage points of all the newly es- tablished subsidiaries of Taiwan’smultination corporations,mainly to Hong Kong, Japan, South Korea, the United States and India. Finally, by simulating a unilateral reduction of tax rates by 15%in each country, we find that the attraction of the tax reform in the United States towards the end of 2017 to Taiwan’s listed companies in choosing the United States as a new subsidiary is disadvantageous to the same tax cuts implemented in China, Hong Kong and Japan.
- Publication
Taiwan Economic Forecast & Policy, 2018, Vol 49, Issue 1, p47
- ISSN
1729-8849
- Publication type
Article