个人所得税是否影响企业基于税收动机的利润转移?

Do personal income taxes affect corporate tax-motivated profit shifting?

Journal of Accounting & Economics · 2024
被引 7
人大 AFT50UTD24ABS 4*

中文导读

研究了个人所得税如何通过提高劳动力成本,抑制跨国公司向低税率国家转移利润的行为,尤其在有严格实质要求时效果更显著。

Abstract

This paper examines the role of personal income taxes on multinationals' corporate tax-induced profit shifting. As mandated in most OECD countries, firms need economic substance in low corporate-tax countries to justify profit shifting to these countries. Because high personal income taxes raise labor costs and thus the cost of providing economic substance, we predict that personal income taxes mute profit shifting. Using data from 26 European countries, we find that personal income taxes substantially reduce profit shifting to low corporate-tax jurisdictions, particularly when parent countries impose strict substance requirements. We also find that firms use employees to justify economic substance and that the effect of the personal income tax is related to its incidence falling partly on firms. Our results show important interactions between personal and corporate income taxes that reduce multinationals’ profit-shifting activities when substance requirements are implemented as in the European Union or many OECD countries.

个人所得税企业利润转移经济实质要求税收互动