Taxation Of Inbound Investment

The purpose of this paper is to review the factors inherent in the Canadian income tax system that impact directly on inbound investment, including the Canadian withholding tax and thin capitalization provisions. This paper discusses the objectives of such provisions, as well as their impact on foreign investment and compares the Canadian income tax regime with respect to such factors to those of the UK, the USA, Germany, Australia and the Netherlands. Comparative study.

This publication reports the results of a project examining taxation and foreign direct investment (FDI).

Drawing on a unique data set (MiDi) on German multinationals provided by the Deutsche Bundesbank in Frankfurt, Mintz and Weichenrieder confirm the prevalence of indirect financing structures for both outbound and inbound German investment. They find evidence of "treaty shopping!' to avoid withholding taxes (using a third country with more favorable tax rates as a conduit through which to route investments) and of "debt shifting." --

This book describes the many different ways in which national tax rules and international tax principles affect foreign direct investment decisions, and examines their impact on the establishment and operation of foreign-invested projects. It focuses on tax provisions in both host and home countries, and looks at the role of tax treaties, the methods of relieving double taxation and of countering tax avoidance.

The 2017 Tax Cuts and Jobs Act (TCJA) sharply reduced effective corporate income tax rates on equity-financed US investment. This paper examines the reform’s impact on US inbound foreign direct investment (FDI) and investment in property, plant and equipment (PPE) by foreign-owned US companies. We first model effective marginal and average tax rates (EMTRs and EATRs) by country, industry, and method of finance, and then use those tax rates to calculate the tax semi-elasticities of inbound FDI and PPE investment. We find that both PPE investment and FDI financed with retained earnings responded positively to the TCJA reform, but FDI financed with new equity or debt did not. In country-level PPE regressions, inclusion of macroeconomic controls renders tax rate coefficients insignificant, suggesting that the increase in PPE investment after TCJA was driven by general economic growth. In regressions of FDI financed with retained earnings, however, tax coefficients were robust to inclusion of macroeconomic controls. As the literature predicts, EATRs have a greater impact on cross-border investment than EMTRs. Country-by-industry regressions showed a larger effect of taxes on PPE investment than aggregate country-level regressions, but industry-level tax rates appear to have no effect on earnings retention.