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Conference object . 2017
SSRN Electronic Journal
Article . 2017 . Peer-reviewed
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Controlled Foreign Corporation Rules and Cross-Border M&A Activity

Authors: Hagen, Dominik von; Prettl, Axel;

Controlled Foreign Corporation Rules and Cross-Border M&A Activity

Abstract

We investigate the influence of one main anti tax avoidance measure, controlled foreign corporation (CFC) rules, on cross-border merger and acquisition (M&A) activity on a global scale. Using three different statistical methods and a large M&A data set, we find that CFC rules distort ownership patterns due to a competitive advantage of multinational entities whose parents reside in non-CFC rule countries. First, we show that the probability of being the acquirer of a low-tax target decreases if CFC rules may be applicable to this target’s income. Second, we show that CFC rules distort the acquirer’s location choice of targets. Third, we show that CFC rules negatively affect the probability of being the acquirer in a cross-border M&A. Altogether, this study shows that for affected acquirer countries, CFC rules lead to less M&A activity in low-tax countries because profit shifting seems to be less feasible. This behavior change could result in an increase in global corporate tax revenue.

Country
Germany
Keywords

330

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    popularity
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    influence
    This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
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    This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
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selected citations
These citations are derived from selected sources.
This is an alternative to the "Influence" indicator, which also reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Citations provided by BIP!
popularity
This indicator reflects the "current" impact/attention (the "hype") of an article in the research community at large, based on the underlying citation network.
BIP!Popularity provided by BIP!
influence
This indicator reflects the overall/total impact of an article in the research community at large, based on the underlying citation network (diachronically).
BIP!Influence provided by BIP!
impulse
This indicator reflects the initial momentum of an article directly after its publication, based on the underlying citation network.
BIP!Impulse provided by BIP!
2
Average
Average
Average
Green
bronze