IMF-国际税收溢出与有形投资——对全球最低税收的启示（英）-2023.8-80页_2mb

Summary of "International Tax Spillovers and Tangible Investment, With Implications for the Global Minimum Tax"

Introduction

This paper analyzes how international taxation affects tangible cross-border investment and explores implications for a global minimum tax rate of 15%, as agreed under the G20/OECD BEPS project. It challenges the use of traditional FDI data and leverages new Foreign Affiliate Investment (FAI) data, which better captures real investment by accounting for conduit flows and ultimately identifying parent companies.

Methodology

• Critiques FDI data due to double-counting and misrepresentation of real investment.
• Develops a new framework using FAI data, which reports tangible capital investment across borders and adjusts for conduit structures.
• Employs an "I-METR" (International Marginal Effective Tax Rate) and examines components like the statutory rate differential.
• Uses a pseudo-Poisson maximum likelihood (PPML) estimator for empirical analysis, augmented with tax and macroeconomic data from various sources, including the IMF and Oxford tax databases.

Key Findings

• Statutory tax rates have substantial effects on tangible investment. Cross-border tax differentials significantly boost investment, with a semi-elasticity estimate of approximately 3.6. This effect is driven by "implicit" profit shifting through real investment decisions, which has been underestimated in previous studies.
• Effects of the host country's own KF-METR (King-Fl Fullerton Marginal Effective Tax Rate) are weak or nonexistent.
• There are no significant cross-border spillover effects from tax rates in other countries, nor from KF-METRs outside the host country.
• The FEEDBACK:- Spillover effects are stronger in integrated markets like the EU but are also significant elsewhere.
• Effects through the statutory rate differential dominate those from explicit profit shifting or other mechanisms.

Implications for the Global Minimum Tax

A 15% global minimum tax rate may not suppress investment; it could actually increase aggregate tangible investment due to the structure of cross-country tax rates. This is contrary to some anticipations and derives from the empirical findings that higher minimum rates shuffling

Conclusion

The paper underscores the significance of tax spillovers in shaping cross-border investment and suggests that policy reforms like the global minimum tax could be designed with implications for investment in mind. FAI data is critical for accurate tax impact analysis, and the findings imply a nuanced understanding of tax effects across countries for better policy-making.