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Corporate tax planning and thin-capitalization rules: evidence from a quasi-experiment

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  • Michael Overesch
  • Georg Wamser

Abstract

This article investigates tax-planning behaviour by means of inter-company finance and the effectiveness of government countermeasures 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 to 2004, confirms a significant impact of tax-rate differentials on the use of inter-company debt. The effectiveness of the German thin-capitalization rule is tested by using legal amendments as natural experiments. The results suggest that thin-capitalization rules induce significantly lower internal borrowing. Hence, tax planning via internal finance is effectively limited by thin-capitalization rules.

Suggested Citation

  • Michael Overesch & Georg Wamser, 2010. "Corporate tax planning and thin-capitalization rules: evidence from a quasi-experiment," Applied Economics, Taylor & Francis Journals, vol. 42(5), pages 563-573.
    • Handle: RePEc:taf:applec:v:42:y:2010:i:5:p:563-573
    DOI: 10.1080/00036840701704477
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    References listed on IDEAS

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    1. Paolo Panteghini, 2009. "The capital structure of multinational companies under tax competition," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 16(1), pages 59-81, February.
    2. Jack Mintz & Alfons J. Weichenrieder & Alfons Weichenrieder, 2005. "Taxation and the Financial Structure of German Outbound FDI," CESifo Working Paper Series 1612, CESifo.
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