Territorial Tax Reform and Profit Shifting by US and Japanese Multinationals

Abstract

In 2009, Japan adopted a territorial tax regime by exempting dividends paid by Japanese-owned foreign subsidiaries to their parent firms from home-country taxation. This paper examines the impact of this tax reform on profit shifting by Japanese multinationals. I find that the semielasticity of pretax profits with respect to host-country corporate tax rates for Japanese-owned foreign subsidiaries, particularly large subsidiaries, increased after the 2008 announcement of the implementation of the territorial tax regime, relative to that for US-owned foreign subsidiaries. This suggests that large Japanese-owned foreign subsidiaries responded to the incentive for profit shifting provided by the territorial tax reform.