Nordic Tax Journal · 2015 · 42 citations · 36 references
LawFinanceCorporate FinanceCorporate TaxationTaxationCapital Structure DeterminantsCapital Structure TheoryComparative Corporate TaxationControlled Foreign Corporation RulesThin CapitalizationThin Capitalization RulesAllowance For Corporate EquityControlled Foreign Company FinancingCross-border Debt ShiftingCross-border Interest DeductibilityDebt Limit RulesInterest Deductibility LimitsInterest Deductibility RulesInterest Deduction Shifting
Abstract This paper presents the general design of thin-capitalization rules and summarizes the economic effects of such rules as identified in theoretical models. We review empirical studies providing evidence on the experience with (German) thin-capitalization rules as well as on the adjustment of German multinationals to foreign thin-capitalization rules. Special emphasis is given to the development in Germany, because Germany went a long way in limiting interest deductibility by enacting a drastic change in its thin-capitalization rules in 2008, and because superb German data on multinational finance allows for testing several aspects consistently. We then discuss the experience of the Nordic countries with thin-capitalization rules. Briefly reviewing potential alternatives as well, we believe that the arm’s-length principle is administratively too costly and impracticable, whereas we argue that controlled-foreign-company rules might be another promising avenue for limiting internal debt shifting. Fundamental tax reforms towards a system with either "allowance for corporate equity" (ACE) or a "comprehensive business income tax" (CBIT) should also eliminate any thin-capitalization incentive.
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Capital structure and international debt shifting
Harry Huizinga, Luc Laeven, Gaëtan Nicodème · Journal of Financial Economics · 2008 · 466 citations
Law, Business Economics, Finance +17