مالیاتهای عودت داده شده، استراتژی عودت و سیاست مالی چند ملیتی

Several investment-repatriation strategies are added to the standard model of a multinational in which an affiliate is located in a low-tax country and is limited to two alternatives: repatriating taxable dividends to the parent or investing in its own real operations. In our model, affiliates can invest in passive assets, which the parent can borrow against, or in related affiliates which can be used as vehicles for tax-favored repatriations. We show analytically how the availability of alternative strategies can effect real investment throughout the worldwide corporation. We use firm level data for US multinationals to test for the importance of alternative strategies. The evidence is generally consistent with the theory, particularly the strategies using related affiliates.

In spite of the widespread interest in globalization, the literature on the behavior of multinational corporations (MNCs) tends to focus on a limited range of financial flows between foreign affiliates and parents.1 In the standard model, the MNC is subject to a credit and deferral tax system at home and typically operates one affiliate in a low-tax country. After capitalizing the affiliate the MNC chooses between direct dividend remittances to the parent and further real investment in the foreign affiliate. Paying dividends is a costly alternative from a tax perspective since these remittances are subject to the higher home country tax rate when received by the parent. However, real investment in the foreign affiliate, which may generate inferior returns relative to investment at home, is only one of many alternatives to direct dividend repatriations. The MNC can engage in a variety of other strategies that have the effect of achieving the equivalent of repatriation without incurring the home country tax on direct repatriations of low-tax income. One alternative to direct repatriation and investment in its real operations is investment in passive assets such as Eurodollar deposits. Depending on the size of the interest yield compared to the MNC’s equity return, this may be as good as direct remittances. Beyond that, even if after-tax interest rates are low compared to equity returns, the MNC can achieve the complete equivalent of a tax-free direct repatriation if the parent can borrow against the passive assets held by the subsidiary. Once borrowing is an option, direct flows between affiliate and parent are no longer necessary — the earnings in the low-tax country can support investment at home without bearing the burden of the US corporate tax.

Several investment-repatriation strategies are added to the standard model of a parent and its affiliate in which the affiliate is limited to two alternatives: repatriating direct dividends to the parent or investing in its own real operations. We showed that the availability of alternative repatriation strategies can have an effect on real investment in the low-tax subsidiary and throughout the worldwide corporation. If low-tax subsidiaries can achieve the equivalent of tax-free repatriations, they do not have to ‘underinvest’ initially to obtain the benefits of deferral. If retained lightly taxed earnings are ‘trapped’ because of the repatriation tax, they are trapped in all foreign subsidiaries as a group, including high-tax ones, because they are able to use the funds. Firm level balance sheet and payment data for US multinational corporations and their affiliates show the importance of these alternative strategies. The evidence is generally consistent with the theory, particularly the ‘triangular’ strategies using related affiliates. Controlled foreign corporations that face high repatriation taxes make greater investments in related affiliates and send a greater share of their dividends to other foreign affiliates. In addition, they also pay off more local debt as they accumulate retained earnings which is another version of the ‘passive assets’ strategy considered in our analytical model.