Does withholding tax on interest limit international profit-shifting by FDI?
Does withholding tax on interest limit international profit-shifting by FDI?

Summary/Abstract: Research background: Poland is a significant recipient of intercompany loans as a part of foreign direct investment (FDI) debt instruments reported in the Balance of Payments. Most of them come from the developed West European countries — Netherlands, Luxembourg, France, Germany, and Belgium. Igan et al. (2020) confirm debt-based FDI inflows to emerging markets had a higher impact on the industries’ growth in the pre-crisis period 1998–2007 than after (till 2010). Purpose of the article: We aim to identify withholding tax (WHT) impact on intercorporate loans inflow to Poland and analyse the relationship between trade credit and intercompany loans to assess the importance of the profit-shifting role of FDI after 2010. Methods: To reflect the impact of withholding tax and trade credit on inter-company loans (in-ward debt-based FDI) in 2011–2017 to Poland, we use Arellano-Bond and random effects panel model estimators. The estimated specification is derived from the knowledge-capital model and includes two types of capital: human and physical. Findings & value-added: We show that WHT on interests reduces profit-shifting by multinational companies’ intercompany lending to Poland. But intercompany loans are positively related to foreign trade credit. Unlike in the case of total FDI inward to Poland (Cieślik, 2019), we identified that vertically integrated multinational enterprises are more likely to provide loans to Polish firms. This study is the first to confirm that withholding tax of interests reduces international profit-shifting by FDI and to provide evidence on the relationship between foreign trade credit and intercompany loans provided by multi-national companies.

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