China's new Corporate Income Tax Law was passed in March 2007 and took effect on January 1, 2008. It terminated the dual corporate income tax regime by removing the preferential tax treatments offered to foreign investment enterprises (FIEs) and unifying the corporate income tax regime for FIEs...

The study analyses the incentives for multinationals caused by linking different national tax systems. The dividend tax capitalization hypothesis is extended to include taxes during the repatriation and onward distribution (as equalization tax) to derive the relevant cost of capital formulae for...

The theory of tax competition suggests that different tools might be used to attract physical capital and taxable profits. While it is assumed that FDI in real activity is deterred by high effective taxes, investment undertaken for purpose of profit-shifting is deterred by a higher statutory tax...

This manuscript develops a model that incorporates income shifting into investments by U.S. multinationals in their foreign subsidiaries. The model demonstrates that, while there is always an incentive to shift income into the U.S. from high foreign tax rate subsidiaries, income shifting out of...

Cederwall discusses the Tax Foundation's virtual colloquium, "Making Sense of Profit Shifting" — featuring 18 leading tax scholars, practitioners, and policy experts — and explains how it reveals six significant themes of incongruence in the understanding of profit shifting. Cederwall...

We show that corporate taxation systems regarding foreign dividends and capital gains across 49 countries differ in many aspects, contradicting the requirements for capital ownership neutrality and indicating that ownership patterns are distorted. Consequently, a national tax policy maker may...

This paper provides direct evidence of profit shifting to low tax jurisdictions by multinational companies through transfer prices. Using detailed firm level export and import data by origin/destination and product for France, I show that the price wedge between arm's length and related party...

Using pairs of similar US and European firms listed on the S&P500 or StoxxEurope600, we examine effective tax differentials between US multinational corporations (MNCs) and their European peers. We show that statutory tax rates and profit shifting opportunities are important determinants of...

This paper presents the first analysis of transfer pricing strategies, employing a simulated proxy for the company's marginal tax rate. Application of this sophisticated tax measure allows us to perform a direct comparison of profit shifting to subsidiaries with low statutory tax rates and to...

This paper investigates multinational enterprises' (MNEs) response to a unique window of opportunity for temporarily unrestricted profit shifting. The window unexpectedly opened because of a ruling by the European Court of Justice in 2006 that suspended the application of controlled foreign...