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The Capitalization Rules And Multinational Firm Capital Structure
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Book Synopsis Thin Capitalization Rules and Multinational Firm Capital Structure by : Jennifer Blouin
Download or read book Thin Capitalization Rules and Multinational Firm Capital Structure written by Jennifer Blouin and published by International Monetary Fund. This book was released on 2014-01-24 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the impact of thin capitalization rules that limit the tax deductibility of interest on the capital structure of the foreign affiliates of US multinationals. We construct a new data set on thin capitalization rules in 54 countries for the period 1982-2004. Using confidential data on the internal and total leverage of foreign affiliates of US multinationals, we find that thin capitalization rules significantly affect multinational firm capital structure. Specifically, restrictions on an affiliate’s debt-to-assets ratio reduce this ratio on average by 1.9%, while restrictions on an affiliate’s borrowing from the parent-to-equity ratio reduce this ratio by 6.3%. Also, restrictions on borrowing from the parent reduce the affiliate’s debt-to-assets ratio by 0.8%, which shows that rules targeting internal leverage have an indirect effect on the overall indebtedness of affiliate firms. The impact of capitalization rules on affiliate leverage is higher if their application is automatic rather than discretionary. Furthermore, thin capitalization regimes have aggregate firm effects: they reduce the firm’s aggregate interest expense but lower firm valuation. Overall, our results show than thin capitalization rules, which thus far have been understudied, have a substantial effect on the capital structure within multinational firms, with implications for the firm’s market valuation.
Book Synopsis Thin Capitalization Rules and Multinational Firm Capital Structure by :
Download or read book Thin Capitalization Rules and Multinational Firm Capital Structure written by and published by . This book was released on 2014 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis Thin Capitalization Rules and Multinational Firm Capital Structure by : Jennifer Blouin
Download or read book Thin Capitalization Rules and Multinational Firm Capital Structure written by Jennifer Blouin and published by . This book was released on 2014 with total page 47 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the impact of thin capitalization rules that limit the tax deductibility of interest on the capital structure of the foreign affiliates of US multinationals. We construct a new data set on thin capitalization rules in 54 countries for the period 1982-2004. Using confidential data on the internal and total leverage of foreign affiliates of US multinationals, we find that thin capitalization rules affect multinational firm capital structure in a significant way. Specifically, restrictions on an affiliate's debt-to-assets ratio reduce this ratio on average by 1.9%, while restrictions on an affiliate's borrowing from the parent-to-equity ratio reduce this ratio by 6.3%. Also, restrictions on borrowing from the parent reduce the affiliate's debt to assets ratio by 0.8%, which shows that rules targeting internal leverage have an indirect effect on the overall indebtedness of affiliate firms. The impact of capitalization rules on affiliate leverage is higher if their application is automatic rather than discretionary. Furthermore, we show that thin capitalization regimes have aggregate firm effects: they reduce the firm's aggregate interest expense bill but lower firm valuation. Overall, our results show than thin capitalization rules, which thus far have been understudied, have a substantial effect on the capital structure within multinational firms, with implications for the firm's market valuation.
Book Synopsis The Capitalization Rules and Multinational Firm Capital Structure by : Jennifer Blouin
Download or read book The Capitalization Rules and Multinational Firm Capital Structure written by Jennifer Blouin and published by . This book was released on 2014 with total page 47 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis The Impact of Thin-Capitalization Rules on Multinationals' Financing and Investment Decisions by : Thiess Büttner
Download or read book The Impact of Thin-Capitalization Rules on Multinationals' Financing and Investment Decisions written by Thiess Büttner and published by . This book was released on 2016 with total page 56 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper analyzes the effectiveness of thin-capitalization rules in preventing debt finance by intercompany loans and explores their consequences for corporate decisions. A theoretical discussion emphasizes that limitations of the deduction of interest owed to foreign affiliates would not only affect multinationals' capital structure choice but also investment. An empirical investigation exploits a large firm-level panel dataset of multinationals in order to analyze the impact of thin-capitalization rules on capital structure choice and investment in the OECD and some further European countries in the time period between 1996 and 2004. The results indicate that thin-capitalization rules are effective in curbing tax planning via intercompany loans. However, investment is found to be adversely affected.
Book Synopsis Thin Capitalization Rules and Multinational Firm Capital Structure by : Jennifer Blouin
Download or read book Thin Capitalization Rules and Multinational Firm Capital Structure written by Jennifer Blouin and published by International Monetary Fund. This book was released on 2014-01-24 with total page 37 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the impact of thin capitalization rules that limit the tax deductibility of interest on the capital structure of the foreign affiliates of US multinationals. We construct a new data set on thin capitalization rules in 54 countries for the period 1982-2004. Using confidential data on the internal and total leverage of foreign affiliates of US multinationals, we find that thin capitalization rules significantly affect multinational firm capital structure. Specifically, restrictions on an affiliate’s debt-to-assets ratio reduce this ratio on average by 1.9%, while restrictions on an affiliate’s borrowing from the parent-to-equity ratio reduce this ratio by 6.3%. Also, restrictions on borrowing from the parent reduce the affiliate’s debt-to-assets ratio by 0.8%, which shows that rules targeting internal leverage have an indirect effect on the overall indebtedness of affiliate firms. The impact of capitalization rules on affiliate leverage is higher if their application is automatic rather than discretionary. Furthermore, thin capitalization regimes have aggregate firm effects: they reduce the firm’s aggregate interest expense but lower firm valuation. Overall, our results show than thin capitalization rules, which thus far have been understudied, have a substantial effect on the capital structure within multinational firms, with implications for the firm’s market valuation.
Book Synopsis The Impact of Thin-Capitalization Rules on Multinationals' Financing and Investment Decisions by : Thiess Buettner
Download or read book The Impact of Thin-Capitalization Rules on Multinationals' Financing and Investment Decisions written by Thiess Buettner and published by . This book was released on 2008 with total page 34 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper analyzes the role of Thin-Capitalization rules for capital structure choice and investment decisions of multinationals. A theoretical analysis shows that the imposition of such rules tends to affect not only the leverage and the level of investment but also their tax-sensitivity. An empirical investigation of leverage and investment reported for affiliates of German multinationals in 24 countries in the period between 1996 and 2004 offers some support for the theoretical predictions. While Thin-Capitalization rules are found to be effective in restricting debt finance, investment is found to be more sensitive to taxes if debt finance is restricted.
Book Synopsis The Impact of Thin-capitalization Rules on Multinationals' Financing and Investment Decisions by : Thiess Büttner
Download or read book The Impact of Thin-capitalization Rules on Multinationals' Financing and Investment Decisions written by Thiess Büttner and published by . This book was released on 2008 with total page 46 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis At A Cost: The Real Effects of Thin Capitalization Rules by : Ruud A. de Mooij
Download or read book At A Cost: The Real Effects of Thin Capitalization Rules written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2021-02-05 with total page 17 pages. Available in PDF, EPUB and Kindle. Book excerpt: Thin capitalization rules (TCRs) aim to mitigate profit shifting by multinational corporations (MNCs) but, by raising the cost of capital for affected affiliates, can also negatively affect real investment. Exploiting unique panel data on multinational companies in 34 countries during 2006-2014, we estimate that the size of this adverse investment effect can be large, and dependent on the statutory corporate tax rate and the tightness of the safe-haven ratio. Negative investment effects are more pronounced for highly-levered firms for which TCRs are more likely to be binding.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2016 Update Inclusive Framework on BEPS by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2016 Update Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2016-12-22 with total page 212 pages. Available in PDF, EPUB and Kindle. Book excerpt: The 2015 Report on BEPS Action 4 established a common approach which directly links an entity’s net interest deductions to its level of economic activity, based on taxable EBITDA. Further work on two aspects of the common approach was completed in 2016 and this is included in this update.
Book Synopsis Capital Structure and Corporate Governance by : Lorenzo Sasso
Download or read book Capital Structure and Corporate Governance written by Lorenzo Sasso and published by Kluwer Law International B.V.. This book was released on 2013-08-01 with total page 248 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite a clear distinction in law between equity and debt, the results of such a categorization can be misleading. The growth of financial innovation in recent decades necessitates the allocation of control and cash-flow rights in a way that diverges from the classic understanding. Some of the financial instruments issued by companies, so-called hybrid instruments, fall into a grey area between debt and equity, forcing regulators to look beyond the legal form of an instrument to its practical substance. This innovative study, by emphasizing the agency relations and the property law claims embedded in the use of such unconventional instruments, analyses and discusses the governance regulation of hybrids in a way that is primarily functional, departing from more common approaches that focus on tax advantages and internal corporate control. The author assesses the role of hybrid instruments in the modern company, unveiling the costs and benefits of issuing these securities, recognizing and categorizing the different problem fields in which hybrids play an important role, and identifying legal and contracting solutions to governance and finance problems. The full-scale analysis compares the U.K. law dealing with hybrid instruments with the corresponding law of the most relevant U.S. jurisdictions in relation to company law. The following issues, among many others, are raised: decisions under uncertainty when the risks of opportunism of the parties is very high; contract incompleteness and ex post conflicts; protection of convertible bondholders in mergers and acquisitions and in assets disposal; use of convertible bonds to reorganise and restructure a firm; timing of the conversion and the issuer’s call option; majority-minority conflict in venture capital financing; duty of loyalty; fiduciary duties to preference shareholders; and financial contract design for controlling the board’s power in exit events. Throughout, the analysis includes discussion, comparison, and evaluation of statutory provisions, existing legal standards, and strategies for protection. It is unlikely that a more thorough or informative account exists of the complex regulatory problems created by hybrid financial instruments and of the different ways in which regulatory regimes have responded to the problems they raise. Because business parties in these jurisdictions have a lot of scope and a strong incentive to contract for their rights, this book will also be of uncommon practical value to corporate counsel and financial regulators as well as to interested academics.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Limiting Base Erosion Involving Interest Deductions and Other Financial Payments, Action 4 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 4.
Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Measuring and Monitoring BEPS, Action 11 - 2015 Final Report by : OECD
Download or read book OECD/G20 Base Erosion and Profit Shifting Project Measuring and Monitoring BEPS, Action 11 - 2015 Final Report written by OECD and published by OECD Publishing. This book was released on 2015-10-05 with total page 272 pages. Available in PDF, EPUB and Kindle. Book excerpt: Addressing base erosion and profit shifting (BEPS) is a key priority of governments. In 2013, OECD and G20 countries, working together on an equal footing, adopted a 15-point Action Plan to address BEPS. This publication is the final report for Action 11.
Book Synopsis Curbing Corporate Debt Bias by : Ruud A. de Mooij
Download or read book Curbing Corporate Debt Bias written by Ruud A. de Mooij and published by International Monetary Fund. This book was released on 2017-02-10 with total page 20 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax provisions favoring corporate debt over equity finance (“debt bias”) are widely recognized as a risk to financial stability. This paper explores whether and how thin-capitalization rules, which restrict interest deductibility beyond a certain amount, affect corporate debt ratios and mitigate financial stability risk. We find that rules targeted at related party borrowing (the majority of today’s rules) have no significant impact on debt bias—which relates to third-party borrowing. Also, these rules have no effect on broader indicators of firm financial distress. Rules applying to all debt, in contrast, turn out to be effective: the presence of such a rule reduces the debt-asset ratio in an average company by 5 percentage points; and they reduce the probability for a firm to be in financial distress by 5 percent. Debt ratios are found to be more responsive to thin capitalization rules in industries characterized by a high share of tangible assets.
Book Synopsis International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots by : Sebastian Beer
Download or read book International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots written by Sebastian Beer and published by International Monetary Fund. This book was released on 2018-07-23 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.
Book Synopsis BRICS and International Tax Law by : Peter Antony Wilson
Download or read book BRICS and International Tax Law written by Peter Antony Wilson and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: With the ongoing expansion of outbound foreign direct investment (FDI) in the countries representing the BRICS economic bloc (Brazil, Russia, India, China, and South Africa) – and with all of them at the same time listed among the top seven countries plagued by tax evasion and avoidance in the guise of illicit out ows – the ve governments, both individually and through cooperative initiatives, have devised new international tax strategies that are proving to be of great interest and value to other countries, both developing and developed. The core of these strategies addresses the necessity of stemming the out ow of revenue while strongly supporting FDI, both inbound and outbound while complying with international obligations including those arising from human rights laws. This book is the rst in-depth commentary on this new and evolving area of international tax law. The detailed analysis covers the entire eld of BRICS international tax law, considering topics such as the following: – information exchange procedures and pitfalls; – response to the OECD’s Base Erosion and Pro t-Sharing (BEPS) initiative; – role of bilateral and multilateral double taxation conventions including the Multilateral Instrument and the Bilateral Investment Treaties; – thin capitalization; – transfer pricing; – controlled foreign corporation rules; – shortcomings related to authorities’ limited manpower; – international audit and investigation procedures; – the BRICS approach to residence and mandatory and binding arbitration; and – the BRICS approach to shaping the developing world’s international tax system. Notably, the author personally conducted interviews with senior international representatives of the BRICS tax authorities, as well as with leading BRICS academics and practitioners. Tax cases, together with human rights and investment cases and administrative guidelines in all ve countries are also included in the analysis. The study concludes with recommendations for improving each of the ve countries’ tax law and procedures, especially in the area of dispute resolution. The author’s goal is to extend the existing body of knowledge of the BRICS’ international tax laws in order to assist in developing an understanding of the BRICS approach to dealing with evasion and avoidance: an approach which facilitates both outbound and inbound FDI, simpli es tax authority administration and establishes a basis for resolving international disputes which is compatible with sovereignty. In achieving this objective, the author has produced a major work that is of immeasurable value to tax advisers, government and governance of cials, academics and researchers both in developing international taxation strategies and in helping to resolve disputes with tax authorities.
Book Synopsis Multilateral Cooperation in Tax Law by : Martin Klokar
Download or read book Multilateral Cooperation in Tax Law written by Martin Klokar and published by Linde Verlag GmbH. This book was released on 2023-10-03 with total page 357 pages. Available in PDF, EPUB and Kindle. Book excerpt: An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bridge between the states’ demand for sovereignty and the problems caused by BEPS. In this regard, the OECD, the UN, and the EU play an important role in introducing international tax standards in an attempt to effectively address tax evasion and aggressive tax planning in many ways. The interaction and cooperation between different international, supranational (EU), and regional organizations is an ongoing process. In this context, the topic "Multilateral Cooperation in Tax Law" was selected as the general topic for the master’s theses of the part-time 2021-23 class of the postgraduate LL.M. programme in International Tax Law at WU (Vienna University of Economics and Business). This volume aims to develop academic insights, provide practical guidance, and enable an in-depth analysis of various aspects of this topic. The book is divided into four parts. The first part deals with a general overview of the understanding of multilateral cooperation, the background that led to the need for multilateral cooperation and the different stakeholders that play a relevant role in it. While the chapters included in the second part focus on the most important developments on an international level (OECD and UN), the chapters encompassed in the third part analyse the multilateral cooperation initiatives of the EU. Finally, the chapters included in part four deal with selected issues related to multilateral cooperation in tax law, including mutual assistance and exchange of information, dispute resolution mechanisms, and measures in digitalized businesses.
