Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/73764 
Year of Publication: 
2006
Series/Report no.: 
ifo Working Paper No. 37
Publisher: 
ifo Institute - Leibniz Institute for Economic Research at the University of Munich, Munich
Abstract: 
This paper investigates tax planning behavior by means of inter-company finance and the effectiveness of fighting back via thin-capitalization rules. A simple theoretical model, which considers the financing decision of a multinational company, is used to obtain empirical implications. The empirical analysis, based on German inbound investment data from 1996 until 2004, supports a significant impact of tax rate differences on the use of intra-company debt. The effectiveness of the German thin-capitalization rule is tested by using legal amendments as natural experiments. The results suggest that the German thin-capitalization rule induces significantly lower intra-firm debt-levels of inbound investments. Hence, tax planning via intra-firm finance is effectively limited.
Subjects: 
Corporate income tax
multinationals
thin-capitalization rule
difference-indifferences
firm-level data
JEL: 
G32
H25
H26
Document Type: 
Working Paper

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