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http://dx.doi.org/10.23895/kdijep.2022.44.3.27

The Impact of Tax Treaties on Foreign Direct Investment: The Evidence Reconsidered  

LEE, SIWOOK (KDI School of Public Policy)
KIM, DAEYONG (Division of Development Research, Korea Development Institute)
Publication Information
KDI Journal of Economic Policy / v.44, no.3, 2022 , pp. 27-48 More about this Journal
Abstract
This paper reconsiders the empirical evidence of the relationship between tax treaties and FDI using U.S. outbound FDI to 78 countries over the period of 2007-2018. Unlike previous studies, we explicitly consider differences in the tax environments of recipient economies, including their tax-haven status, transfer pricing rules, CFC rules and anti-avoidance regulations, in our estimations. Our results confirm the importance of controlling for country-specific tax environments, especially the tax-haven status and transfer pricing rules. We find that tax treaties positively contribute to FDI inflows in developing countries, while they have no statistically significant impacts on OECD countries. Recently signed tax treaties still foster FDI but less than older ones do. Finally, our results indicate, all other things being equal, that the weaker the transfer pricing regulations, the greater the amount of U.S. direct investment into a non-OECD economy.
Keywords
Tax Treaties; Foreign Direct Investment; Tax Havens; Transfer Pricing; Tax Regulations;
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1 van't Riet, M. and A. Lejour. 2018. "Optimal tax routing: network analysis of FDI diversion," International Tax and Public Finance, 25(5): 1321-1371.   DOI
2 Garcia-Bernardo, J. et al. 2017. "Uncovering offshore financial centers: conduits and sinks in the global corporate ownership network," Scientific Reports, 7(6246): 1-10.   DOI
3 Hong, S. 2018. "Tax treaties and foreign direct investment: A network approach," International Tax and Public Finance, 25(5): 1277-1320.   DOI
4 Kysar, R. M. 2020. "Unraveling the tax treaty," Minnesota Law Review, 104(4): 1755-1837
5 Kobetsky, M. 2011. International taxation of permanent establishment: principles and policy, Cambridge University Press.
6 Lejour, A. 2014. "The foreign investment effects of tax treaties," Working paper No. 1403, Oxford University Centre for Business Taxation.
7 Mundlak, Y. 1978. "On the pooling of time series and cross section data," Econometrica, 46: 69-85.   DOI
8 Kumas, A. and D.L. Millimet. 2018. "Reassessing the effects of bilateral tax treaties on US FDI activity," Journal of Economics and Finance, 42(3): 451-470.   DOI
9 Leduc, S. and G. Michielse. 2021. "Are tax treaties worth it for developing economies?" in R. de Mooij et al. (eds.), Corporate income taxes under pressure; Why reform is needed and how it could be designed. Washington, DC; International Monetary Fund.
10 Neumayer, E. 2007. "Do double taxation treaties increase foreign direct investment to developing countries?" Journal of Development Studies, 43(8): 1501-1519.   DOI
11 Novy, D. 2013. "Gravity redux: measuring international trade costs with panel data," Economic Inquiry, 51(1): 101-121.   DOI
12 Petkova, K. et al. 2020. "On the relevance of double tax treaties," International Tax and Public Finance, 27(3): 575-605.   DOI
13 Schanz, D., S. Keller, A. Dinkel. J. Fritz, and C. Grosselfinger. 2017. The tax attractiveness index: Methodology.
14 Sheppard, L. 2009. "Don't Ask, Don't Tell, Part 4: Ineffectual Information Sharing," Tax Notes: 1411-1418.
15 Stein, E. and C. Daude. 2007. "Longitude matters: time zones and the location of foreign direct investment," Journal of International Economics, 71: 96-112.   DOI
16 Thuronyi, V. 1999. "International tax cooperation and a multilateral treat," Brooklyn Journal of International Law, 26(4): 1641-1681.
17 Anderson, J. E. and E. van Wincoop. 2003. "Gravity with gravitas: A solution to the border puzzle," the American Economic Review, 93(1): 170-192.   DOI
18 Arellano, M. and S. Bond. 1991. "Some Tests of Specification for Panel Data: Monte Carlo Evidence and an Application to Employment Equations," Review of Economic Studies, 58(2): 277-297.   DOI
19 Baker, P. L. 2014. "An analysis of double taxation treaties and their effect on foreign direct investment," International Journal of the Economics of Business, 21(3): 341-377.   DOI
20 Barthel et al. 2010. "The impact of double taxation treaties on foreign direct investment: evidence from large dyadic panel data," Contemporary Economic Policy, 28(3): 366-377.   DOI
21 Blonigen, B. A. and R. B. Davies. 2005. "Do bilateral tax treaties promote foreign direct investment?" in J. Hartigan (ed.), Handbook of international trade: economic and legal analysis of Laws and Institutions, Blackwell Publishing, Oxford.
22 Brooks, K. and R. Krever. 2015. "The troubling role of tax treaties," in G. M. M. Michielse and V. Thuronyi (eds.), Tax design issues worldwide, Series on International Taxation, Vol. 51: 159-178.
23 Carr, D., J. R. Markusen, and K. E. Maskus. 2001. "Estimating the knowledge-capital model of the multinational enterprise," American Economic Review, 91: 693-708.   DOI
24 Davies, R. B. 2003. "Tax treaties, renegotiations, and foreign direct investment," Economic Analysis and Policy, 33: 251-273.   DOI
25 De Mello Jr, L. R. 1997. "Foreign direct investment in developing countries and growth: A selective survey," The Journal of Development Studies, 34(1): 1-34.   DOI
26 Egger, P., M. Larch, M. Pfaffermayr, and H. Winner. 2006. "The impact of endogenous tax treaties on foreign direct investment: Theory and evidence," Canadian Journal of Economics 39(3): 901-931.   DOI
27 Feld, L. P. and J. H. Heckemeyer. 2011. "FDI and taxation: a meta-study," Journal of Economic Surveys, 25(2): 233-272.   DOI
28 Blonigen, B. A. and R. B. Davies. 2004. "The effects of bilateral tax treaties on U.S. FDI activity," International Tax and Public Finance, 11(5): 601-622.   DOI