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Immobilizing Corporate Income Shifting: Should It Be Safe to Strip in the Harbor?

Gresik, Thomas A.; Schindler, Dirk; Schjelderup, Guttorm
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URI
http://hdl.handle.net/11250/2364462
Date
2015-11-18
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  • Discussion papers (FOR) [556]
Abstract
Many subsidiaries can deduct interest payments on internal debt from their taxable income. By issuing internal debt from a tax haven, multinationals can shift income out of host countries through the interest rates they charge and the amount of internal debt they issue. We show that, from a welfare perspective, thin-capitalization rules that restrict the amount of debt for which interest is tax deductible (safe harbor rules) are inferior to rules that limit the ratio of debt interest to pre-tax earnings (earnings stripping rules), even if a safe harbor rule is used in conjunction with an earnings stripping rule.
Publisher
FOR
Series
Discussion paper;31/15

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