期刊名称：Departmental Discussion Papers / University of Glasgow, Department of Economics
出版年度：2008
卷号：1
出版社：University of Glasgow, Department of Economics
摘要：In this paper we show that the ability of multinational ¡¥rms to manipulate transfer
prices a.ects the tax sensitivity of foreign direct investment (FDI). We o.er a model of in-
ternational capital allocation where ¡¥rms are heterogeneous in their ability to manipulate
transfer prices. Perhaps paradoxically, we show that the ability to shift pro¡¥ts can make
parent companies' investment more sensitive to host-country tax rates, as long as investors
expect ¡¥scal authorities to use price and pro¡¥t detection methods. We then o.er a com-
prehensive empirical study to test our predictions in the case of Japanese FDI. We exploit
the ¡¥nding that the unobservable ability to manipulate transfer prices is correlated with
whole ownership of a¡Àliates and R&D expenditure. Based on country, parent ¡¥rm and
sector characteristics, we estimate an investment equation on a sample of 3614 Japanese
a¡Àliates in 49 emerging countries. We obtain a greater semi-elasticity of investment to
the statutory tax rate in a¡Àliates that are wholly-owned and that have R&D intensive
parents. We interpret these results as indirect evidence that abusive transfer pricing is
one of the determinants of FDI activity.
关键词：International Taxation, Transfer Pricing, FDI, Ownership Structure, R&D,
Japanese Investment, Tax Sparing.
