Corporate Tax Incentives for Foreign Direct Investment (Oecd by OCED

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Additional resources for Corporate Tax Incentives for Foreign Direct Investment (Oecd Tax Policy Studies, 4)

Example text

In practice, this targeting is very difficult to sustain, as existing firms attempt to recharacterise their business activities to qualify for the tax relief. 7. , a reduction in share values for) existing capital holders (for the same reason that the value or price of any other asset declines, ceteris paribus, if the purchase price of a new unit falls). 8. Financing incentives may also be targeted at non-resident portfolio investors. See the OECD report Taxation of Cross-Border Portfolio Investment – Mutual Funds and Possible Tax Distortions, 1999, for a discussion of relevant portfolio shareholder tax considerations and the impact of tax relief in international direct (non-intermediated) and intermediated (collective investment fund) investment structures.

Consider a parent company in an insufficient foreign tax credit position that invests a dollar of new equity capital into a subsidiary and reinvests the after-tax profits (which will defer payment of home country tax on those profits). Let R denote the pre-tax rate of return at source on the investment, and u* denote the host country average effective corporate income tax rate which is lower than the host country basic (statutory) corporate income tax rate on account of some combination of a targeted tax rate reduction, accelerated and/or enhanced depreciation allowances, tax credits, or a corporate tax holiday.

One the one hand, the granting of incentives by discretion (with pre-approval of authorities) may be attractive, in that it may improve targeting to desired activities, reduce the scope for tax avoidance, limit up-take and more generally limit the revenue cost. However, the approval process may be time-consuming and cumbersome. Administration discretion can also undermine transparency of the tax system, leading to a sense of unfairness, and tend to increase uncertainty with negative investment incentive effects.

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