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Business and Economics > Corporate Taxation

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Cover IMF Working Papers
Macroeconomic Effects of Dividend Taxation with Investment Credit Limits
Matteo Ghilardi
and
Roy Zilberman
We analyze the effects of dividend taxation in a general equilibrium business cycle model with an occasionally-binding investment credit limit. Permanent dividend tax reforms distort capital investment decisions in the binding long-run equilibrium, but are neutral otherwise. Temporary unexpected tax cuts stimulate shortterm real activity in the credit-constrained economy, yet produce contractionary macroeconomic outcomes in the slack regime. The occasionally-binding constraint reconciles the `traditional' and `new' views of dividend taxation, and highlights the importance of measuring the firm's initial borrowing position before enacting tax reforms. Finally, permanently lower dividend taxes dampen financial business cycles, and help to explain macroeconomic asymmetries.
Keywords:
Dividend Taxation; Occasionally-Binding Borrowing Constraints; Investment; Business Cycles.; borrowing position; tax relief; dividend distribution; dividend tax rate; dividend tax adjustment; tax environment; benchmark system; dividend tax shock; dividend tax cut; tax adjustment; dividend tax system; Dividend tax; Credit; Corporate income tax; Collateral; Stocks
Cover IMF Working Papers
Tax Elasticity Estimates for Capital Stocks in Canada
Jean-François Wen
,
Fatih Yilmaz
, and
Danea Trejo
The paper provides estimates of the long-run, tax-adjusted, user cost elasticity of capital (UCE) in a small open economy, exploiting three sources of variation in Canadian tax policy: across provinces, industries, and years. Estimates of the UCE with Canadian data are less prone to the endogeneity problems arising from the effects of tax policy changes on the interest rate or on the price of capital equipment. Reductions in the federal corporate income tax rate during the early 2000s for service industries but not for manufacturing, which already benefited from a preferential tax rate, contribute to the identification of the UCE. To capture the long-run relationship between the capital stock and the user cost of capital, an error correction model (ECM) is estimated. Supplementary results are obtained from a distributed lag model in first differences (DLM). With the ECM, our baseline UCE for machinery and equipment (M&E) is -1.312. The corresponding semi-elasticity of the stock of M&E with respect to the METR is about -0.2, suggesting, for example, that a 5 percentage point reduction in the METR, say from 15 to 10 percent, would in the long run generate an increase of 1.0 percent in the stock of M&E. The UCE for non-residential construction is statistically insignificantly different from zero.
Keywords:
WP; cost of capital; open economy; user cost of capital; rate of return; UCE estimate; investment tax credit; depreciation rate; Metr data; elasticities decrease; provincial sales tax; differenced GDP terms; machinery and equipment; Marginal effective tax rate; Stocks; Corporate income tax; Real interest rates; Tax allowances; Global; Capital Taxation; User Cost of Capital Elasticity
Cover IMF Working Papers
Exploring Residual Profit Allocation
Sebastian Beer
,
Ruud A. de Mooij
,
Mr. Shafik Hebous
,
Mr. Michael Keen
, and
Ms. Li Liu
Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.
Keywords:
WP; routine profits; capital stock; closed economy; cost function; earnings before interest and taxes; Residual Profit Allocation; International Corporate Taxation; Multinational Firms; profit shifting; residual profits; RPA scheme; purged profits; Marginal effective tax rate; Corporate income tax; Income; Stocks; Global
Cover IMF Working Papers
Do Temporary Business Tax Cuts Matter? A General Equilibrium Analysis
William Gbohoui
This paper develops a dynamic general equilibrium model to assess the effects of temporary business tax cuts. First, the analysis extends the Ricardian equivalence result to an environment with production and establishes that a temporary tax cut financed by a future tax-increase has no real effect if the tax is lump-sum and capital markets are perfect. Second, it shows that in the presence of financing frictions which raise the cost of investment, the policy temporarily relaxes the financing constraint thereby reducing the marginal cost of investment. This direct effect implies positive marginal propensities to invest out of tax cuts. Third, when the tax is distortionary, the expectation of high future tax rates reduces the expected marginal return on investment mitigating the direct stimulative effects.
Keywords:
WP; proportional tax; Ricardian Equivalence; Corporate Tax Policy; Financing Friction; General Equilibrium; dividend constraint; equity issuance; dividend payment; irrelevance theorem; proportional tax tax rate; net investment effect; investment effect; dividend policy irrelevance theorem; firm investment; investment equation; financing constraint; financing decision; Stocks; Corporate income tax; Return on investment
Cover IMF Working Papers
A Destination-Based Allowance for Corporate Equity
Mr. Shafik Hebous
and
Mr. Alexander D Klemm
Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.
Keywords:
WP; interest rate; capital stock; Destination-Based Taxation; ACE; ACC; investment goods; notional interest rate; tax competition; interest receipt; competition policy tool; rate of return; border tax; depreciation rate; upfront tax cost; tax saving; Allowance for corporate equity; Value-added tax; Stocks; Discount rates; Corporate income tax; Global; Destination-based allowance; copyright Page; B. profit shifting; based allowance; E. exchange rate
Cover IMF Working Papers
Foreign Direct Investment in New Member State of the EU and Western Balkans: Taking Stock and Assessing Prospects
La-Bhus Fah Jirasavetakul
and
Jesmin Rahman
FDI has played a strong role in the export-led growth of eastern European countries that are now members of the European Union (EU). Largely sourced from advanced Europe, FDI inflows were motivated by the intention to pursue new markets and cost efficiency. Over time, foreign investment has restructured the exports sector in these countries in favor of products that are considered more technology-intensive. As these countries face skills shortage and rising wages, what is needed for FDI to continue playing a strong role? Can the Western Balkan countries, who are not yet EU members and have in recent years stepped up financial incentives and policy initiatives to court investors, emulate the experience? This paper takes stock of the FDI experience of both these groups and tries to estimate their potential gains from additional policy efforts.
Keywords:
WP; FDI inflow; WB country; host country; EU accession; EU country; FDI flow; FDI stock; Foreign direct investment; determinants of FDI; catching-up process; EU New Member States; Western Balkans; gravity model; panel analysis; inflow regression; Corporate income tax; Tax holidays; Manufacturing; Stocks; Global; Europe
Cover Policy Papers
Tax Policy, Leverage and Macroeconomic Stability
International Monetary Fund
Risks to macroeconomic stability posed by excessive private leverage are significantly amplified by tax distortions. ‘Debt bias’ (tax provisions favoring finance by debt rather than equity) has increased leverage in both the household and corporate sectors, and is now widely recognized as a significant macroeconomic concern. This paper presents new evidence of the extent of debt bias, including estimates for banks and non-bank financial institutions both before and after the global financial crisis. It presents policy options to alleviate debt bias, and assesses their effectiveness. The paper finds that thin capitalization rules restricting interest deductibility have only partially been able to address debt bias, but that an allowance for corporate equity has generally proved effective. The paper concludes that debt bias should feature prominently in countries’ tax reform plans in the coming years.
Keywords:
PP; debt shifting; asset ratio; cost of capital; cash flow; debt vulnerability; interest deductibility; debt bias; income tax; double taxation; banking sector; Debt bias; Allowance for corporate equity; Housing prices; Corporate income tax; Stocks; Europe; Global; ACE duplication; house-price volatility; ACE system; Personal income tax
Cover IMF Working Papers
Debt, Taxes, and Banks
Mr. Michael Keen
and
Ruud A. de Mooij
Understanding the impact of the asymmetric tax treatment of debt and equity on the capital structures of financial institutions is critical to shaping and assessing responses to the problem of excessive leverage that underlay the 2009 financial crisis - but there is no empirical evidence to draw on. Guided by a simple model of banks? financing decisions in the presence of both regulatory constraints and tax asymmetries, this paper explores the impact of corporate tax bias on bank leverage, the use of hybrid instruments and regulatory capital ratios for a panel of over 14,000 commercial banks in 82 countries over nine years. On average, the sensitivity of banks? debt choices proves very similar to that of non-financial firms, consistent with rough offsetting of two opposing effects suggested by the theory. As the model predicts, somewhat counter-intuitively, the impact of tax on hybrids is generally weak or insignificant. Responsiveness to taxation varies significantly across banks, however: those holding smaller equity buffers, and larger banks, are noticeably less sensitive to tax.
Keywords:
WP; capital structure; tax rate; Bank taxation; corporate tax; debt bias; leverage; capital requirement; leverage-asset ratio; bank assets; capital structure choice; bank capital structure; Corporate income tax; Capital adequacy requirements; Stocks; Deposit insurance; Tax arrears management; Europe
Cover Staff Discussion Notes
Tax Biases to Debt Finance: Assessing the Problem, Finding Solutions
Ruud A. de Mooij
Staff Discussion Notes showcase the latest policy-related analysis and research being developed by individual IMF staff and are published to elicit comment and to further debate. These papers are generally brief and written in nontechnical language, and so are aimed at a broad audience interested in economic policy issues. This Web-only series replaced Staff Position Notes in January 2011.
Keywords:
SDN; CIT rate; debt issuance; income tax; cost of capital; debt-equity choice; intracompany debt; debt holder; debt-asset ratio; debt level; pre-existing debt; Debt bias; Corporate income tax; Allowance for corporate equity; Comprehensive business income tax; Stocks; Europe
Cover IMF Working Papers
Allowances for Corporate Equity in Practice
Mr. Alexander D Klemm
This paper provides an overview of full and partial allowance for corporate equity (ACE) tax systems in practice. In the recent past, ACE systems have been used in Austria, Croatia, and Italy. Brazil still applies a variant of such a system and Belgium introduced one this year. This paper summarizes the empirical literature on past ACE systems, and provides a theoretical and empirical assessment of the Brazilian ACE variant. The main finding is that the Brazilian reform introduced an ACE system for a minority of firms only, with the majority instead having a system of dividend deductibility. Despite the reduction in the tax preference for debt finance, capital structures have not changed much, but dividends have increased. Investment appears to have benefited from the reform, although the extent to which this was due to the new structure rather than the tax cut is unclear.
Keywords:
WP; ACE system; dividend deductibility; cost of capital; equity finance; ACE tax; ACE variant