| By: |
Petr Jansky (Institute of Economic Studies, Faculty of Social Sciences, Charles University, Opletalova 26, 110 00, Prague, Czech Republic);
Jan Laznicka (Institute of Economic Studies, Faculty of Social Sciences, Charles University, Opletalova 26, 110 00, Prague, Czech Republic) |
| Abstract: |
Much of the foreign direct investment worldwide is affected by one of more
than 3000 bilateral tax treaties. There is an agreement that dividend and
interest payments respond to these tax treaties’ provisions, but evidence is
scarce as to the magnitude of this response. We aim to fill in this gap for as
many countries as possible by estimating the elasticities of dividend and
interest income with respect to withholding tax rates, and the associated
revenue foregone, exploiting the best available cross-country datasets. We
collect information on withholding tax rates from the International Bureau of
Fiscal Documentation; this includes information on EU directives, which imply
zero withholding rates among all the EU member states and Switzerland, in
addition to standard bilateral tax treaties. We combine this detailed
information on withholding tax rates with foreign direct investment data from
the International Monetary Fund, which we use to approximate bilateral
dividend and interest flows; this results in a large panel data set of around
65,000 annual country-pair observations. While also observing heterogeneity in
elasticities across countries, we estimate dividend flows to be highly elastic
in a cross-country regression: a 1% increase in the applicable withholding tax
is associated with a 2.3% - 2.6% decrease in dividend flows. We apply the
elasticities to estimate potential tax revenue foregone. We estimate the
largest annual revenue foregone for the United States (2.3 - 2.9 billion USD)
and Canada (1.4 - 3.2 billion USD), while the investor country behind the
largest revenue foregone is the Netherlands (2.9 – 3.3 billion USD). We
arrive at somewhat lower and less robust estimates for interest income.
Although our headline revenue estimates are, as expected, lower than static
estimates that do not reflect elasticities, we nevertheless show that the
revenue foregone of tax treaties remain non-negligible for some countries. |
| Keywords: |
foreign direct investment, multinational enterprise, tax treaty, double taxation agreement, elasticity, withholding tax |
| JEL: |
F21 F23 H25 H26 H32 |
| Date: |
2019–11 |
| URL: |
http://d.repec.org/n?u=RePEc:fau:wpaper:wp2019_33&r=all |