Please use this identifier to cite or link to this item: http://hdl.handle.net/10419/89634
Authors: 
Ruf, Martin
Weichenrieder, Alfons
Year of Publication: 
2013
Series/Report no.: 
CESifo Working Paper 4461
Abstract: 
In its Cadbury-Schweppes decision of 12 September 2006 (C-196/04), the Court of Justice of the European Union decided that the UK controlled foreign corporation rules, which were implemented to subject low taxed passive income of foreign affiliates to UK corporate tax, implied an infringement of the freedom of establishment. Consequently, many EU countries including Germany changed their legislation. The paper discusses to which extent the ECJ ruling has impacted on the allocation of passive assets in German multinationals. Using firm level data we find evidence for an increased preference for low-tax European countries compared to non-European countries.
Subjects: 
Court of Justice of the European Union
corporation tax
foreign direct investment
CFC regulation
passive investment
JEL: 
H25
H73
Document Type: 
Working Paper

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