双边税收协定的差异化效应

The Differential Effects of Bilateral Tax Treaties

American Economic Journal: Economic Policy · 2014
被引 102
人大 A-ABS 3

中文导读

利用美国企业层面数据,发现双边税收协定通过避免双重征税促进外国直接投资,对使用差异化投入的企业效果更大,且影响现有子公司的销售和新子公司的进入。

Abstract

Bilateral tax treaties (BTTs) are intended to promote foreign direct investment through double-taxation relief. Using BEA firm-level data, we find a positive effect of BTTs on FDI, which is larger for firms that use differentiated inputs. BTTs allow multinational firms to request assistance from treaty partners' governments if they have a grievance about how tax liabilities are determined. These provisions disproportionately benefit firms that use inputs for which an arm's-length price is difficult to observe, since allocation of earnings across countries is more complex. We find differential BTT effects for both sales by existing affiliates and entry of new affiliates.

双边税收协定外国直接投资差异化投入转让定价