1 Introduction

After more than twenty years of empirical research in the relationship between taxes and foreign
direct investment (FDI), there is consensus among most re- searchers that taxes do matter for the
decision of multinational enterprises (MNE) on where and how much to invest. Correspondingly,
policy-makers often rely on the eectiveness of corporate tax policy reforms in order to attract
FDI, and the current debate suggests that they will continue to do so in the future. But, lowering the tax burden on investment necessarily implies a cut in public expenditure or a shift of the
tax burden to other tax bases like e.g. labor or consumption.
Therefore, it is necessary not only to know whether taxes do matter but also how much they do.
In other words, the quantitative dimension of the tax impact on FDI is decisive for the design of
sound tax policy which carefully weighs the bene.ts of a corporate tax reduction to the economy as a whole against the cost.1 The question is: How
much additional investment or production do we get for a given loss of tax revenue?
The purpose of this paper is to measure the elasticity of FDI with respect to corporate tax
reductions. We do so by analyzing the eect of the German tax reform in 2000, which came into
force in January 2001. This reform implied substantial corporate tax rate cuts and broadened the
corporate tax base. A frequently cited goal of the tax reform was to attract foreign direct
investment in order to foster economic growth and mitigate the high unemployment rate. Now,
.ve years after the reform, we ask whether the tax reform reached its goal. We analyze this
question by using the very richMiDi data set fromthe Deutsche Bundesbank with .rm-speci.c
balance sheet data of foreign-held companies. Our analysis contributes to a literature that tries to
clarify the incentive eects of existing tax systems on corporate investment. As corporate
investment is assumed to be crucial for the generation of new jobs and growth, we think that this
question is at the heart of future debates on corporate tax reforms.

2 The German tax reform of 2000

The main goals of the German Tax Reform 2000 were to improve the competit- iveness of .rms
in Germany, to foster investment, to increase Germany.s attract- iveness to foreign investors and
to adapt the corporate tax system to the rules of the EC common market. With regard to the
corporate tax system, the formerly dierent tax rates on retained earnings (40 percent) and

distributed pro.ts (30 percent) were replaced by a single and lower tax rate on all pro.ts (25
percent).
In addition, the reform eliminated a long list of loopholes.4 including local trading taxes
(Gewerbesteuer) the combined statutory tax rate of the old system was 54,3% while the new
combined rate is on average 39,4%, see Spengel (2001). The corporate tax base was broadened
substantially. Therules for thin capitalization of foreign companies and related party .nancing
were tightened. Depreciation allowances were reduced in terms of expected value for
tangible assets, like machines, and structures.
The decline of the statutory tax rate ensures that both the marginal and the average eective tax
rate for all assets decrease with the tax reform of 2000. The tax base broadening for investment
in machines and structures, though, leads to a relative disadvantage for those assets compared
to .nancial and inventory assets.
4For

a complete description of the reform please refer to Keen (2002), Homburg (2000) and Schreiber (2000).

Next to the changes in the corporate tax system the reform lowered the top personal income tax
rate and the imputation system for the taxation of dividends was replaced by a shareholder relief
system, the so called half income method (Hal- beinknfteverfahren) which stipulates that 50%
of the diovidend after corporate tax is subject to personal income taxation.
The reform of the personal income tax system and the change in the integration technique of
corporate and shareholder taxation are important and probably rel- evant for the investment
decision of foreign investors. But, as we lack appropriate data on shareholders, we cannot use
these reform features for our purpose. In the following we will restrict ourselves to the reform of
the corporate tax system itself, but we will discuss in how far the other reform parts might play a
role in shaping the investment process.

3 The theoretical underpinning

This section develops the conceptual framework for our empirical analysis. We have to de.ne the
nature of decisions that multinational companies make and that could potentially be distorted by
taxation. As pointed out by Devereux and Gri th (2003), it is helpful to distinguish three
dimensions of the investment decisions of multinational .rms: The .rst is to decide whether to
export or to produce abroad (internationalization decision). The second decision is where to
produce (location decision). The third decision is how much to produce, or: how much to invest
(investment decision).

Correspondingly, there are two types of tax eects on FDI. First, taxes may reduce the average
return of a project and thus in.uence the internationalization and location decisions by .rms.
Second, taxes may change the user cost of capital and thus have an impact on the investment
decision. Our dataset does not to analyse the internationalization or the location decision of
MNEs. We just observe existing capital stocks and their variation over time. Therefore, our main
focus is on the choice of the optimal capital stock, i.e. the investment decision. However,
discrete jumps in the balance sheet capital stock suggest that we can observe quasi- location
decisions where .rms decide to locate the production of new goods in one country or another. As
explained further below, our analysis will therefore take into account both the marginal and the
average tax burden on investment.
5

3.1 The main hypothesis

Assume that there is an MNE located in a country outside Germany, which has an a liate in
Germany and - potentially - in other countries as well.5 Using a very general formulation, we can
state that the MNE chooses the size of the capital stocks depending on a .nite vector x including
global, country-speci.c, activity- speci.c and .rm-speci.c parameters:
_ = _(K1; :::;Kn) with Kh = Kh (xh) (1)
with h = 1; :::; n. The x is a m _ 1 vector of parameters which are candidates for in.uencing the
investment decision. One of these parameters is supposed to be taxation. Total dierentiation
yields:
dK =
@K
@x1
dx1 + ::: +
@K
@xtax
dxtax + ::: +
@K
@xn
dxm (2)

xtax is some tax variable to be operationalized later on. Held everything else constant, i.e. dxg = 0
8 g 6= tax with g = 1; :::;m, the partial eect of the tax variable on the capital stock K is:
dK dxtax= @K @xtax _ _tax (3)
Our main hypothesis is that taxation has a negative impact on the foreign-held capital stock, i.e.
_tax < 0. There are two channels through which this relation can be established. First, consider the
case in which taxes increase the cost of capital, and assumethat the pre-tax cost of capital does
not depend on country-speci.c characteristics but rather on some world capital market. In this
case the size of the optimal capital stock falls because some marginal investment projects are not
realized any more.
Here, the capital stock of the foreign parent company and the one of the German a liate are not
systematically linked: i.e.

dKh dKh

= 0. Given that the a liate is not liquidity-constrained, the

investment is independent of any factor in.uencing the other a liates, the parent company or
their locations characteristics.
Second, if taxes increase the average tax burden of a given project, the probabil- ity rises that this
project will be realized elsewhere, e.g. in the country of residence of the parent company: dKh
dKh

< 0. In this case, the a liate investment depends on factors in.uencing the other capital

stocks as well, since they change the relative 5This assumption is justi.ed by the type of data that we use.
We only consider foreign
investors which already have a liates in Germany. Thus, the decision is just how much to invest
and not if at all, i.e. not two-fold like in Devereux and Gri th (1998) or in Razin, Rubinstein
and Sadka (2004).
attractiveness of the a liate location. These factors include, in particular, foreign taxes.
Whether FDI are better described by the .rst or the second model has consid- erable policy
implications. Sinn (1990) argues that a country can immunize itself against tax competition by
lowering the eective marginal tax rate to zero and by only taxing intra-marginal pro.ts. This is
true for the .rst model but not for the second. If .rms and/or projects are mobile and not only
capital, i.e. if the second model is valid, there will be no immunization strategy and even the
oppos-ite policy, a tax rate cut cum base broadening strategy, might become optimal, as
is shown in Becker and Fuest (2005). It is one of the objectives of our analysis to .nd hints at
which of the two distinct models performs better in describing the empirical investment data.

The literature often dierentiates between cost-driven investment and market- entry investment,
suggesting that the latter are not or only weakly tax-sensitive.
The idea behind this statement is that every unit of a market-entry investment has some
complementary units of production in another country. In this case, the tax eect is weaker
because domestic taxes only have an impact on the domestic part of the whole investment. In
contrast, cost-driven investment is part of a strategy of disentangling the production chain. If the
goods are not produced in the country under consideration, they will be produced elsewhere.
Proximity to consumers or market-entry reasoning do not play a role.
In principle, these two types of investment could be used as control and treat- ment group in
order to identify the tax impact on investment. The di culty is that the data does not directly
reveal the type of investment. One often used approximation is the dierentiation between
horizontal investment and vertical investment, see e.g. Buch et al. (2005). Horizontal (or intrabranch) investment is
supposed to be realized because of market-entry reasons, vertical (or inter-branch) investment
because of cost dierences. As we will outline later on we do not have any means to dierentiate
between these two, either, due to data limitations.
.

Appendix: Data sources

FDI data
The Deutsche Bundesbank carries out annual full sample surveys on inbound and outbound
direct investment stocks based on the provisions of the German Foreign Trade and Payments
Regulation. Due to this legal regulation, foreign companies with investments in Germany have to
report selected balance sheet information of their German subsidiaries. The balance sheet data
are calculated using the German accounting regulations. Similarly, German multinational
companies have to report the same information about their foreign a liates. For an extensive
description of the database, see Lipponer (2003a) and Lipponer (2003b). The data is available for
the years 1989 to 2003. Time series for individual companies are available for the years 1996 to
2003. In 2002, about 6,000 domestic investors .led reports on around 22,000 foreign subsidiaries
abroad. With respect to inward FDI, in 2002 data are available for about 10,000 a liates in
Germany, in which some 7,000 foreign investors had a participating interest.
For the purpose of our paper we used only the data on inbound FDI. In order to create a balanced
data set, we only use data from 1996 on and exclude all .rms which do not have full coverage of
the whole period 1996-2003. The balanced panel dataset contains 2830 subsidiaries in Germany.
The investors are based in the following countries: France, Belgium, Nether- lands, Luxembourg,
Italy, UK, Ireland, Denmark, Spain, Norway, Sweden, Fin- land, Austria, Switzerland, USA,
Canada, South Korea and Japan. If a subsidiary is owned by investors from dierent countried
we assumed that the home country is the one where the investor with largest share in the
subsidiary comes from. If two or more investors are equal in size, we choose the one from the
country which comes .rst in alphabetic order.
The most important branches of activity in our data set are Manufacturing, Wholesale, Holdings,
Services to Companies and the Financial Services. We con- centrate on incorporated non-public
companies that have either the legal form of a corporation (Aktiengesellschaft (AG)) or a limited
liability company (Gesellschaft mit beschrnkter Haftung (GmbH)).

Tax related data and other data

For the calculation of the economic depreciation rates in equation (10) we adopt the assumptions
reported in Spengel (2001): Intangible assets depreciate over a period of 12.5 years, buildings
over 53 years and machinery over 11 years. To calculate Ai in equation (9), we assume a nominal
interest rate of 10 percent and an in.ation rate of 3.5 percent. These values are adopted from
Devereux, Grif- 31 .th and Klemm (2002) who also provide the data on other
countries.depreciation allowances and statutory tax rates. The _i are taken from branch-speci.c
aggregate data of the Deutsche Bundes- bank15 assuming that the a liates held by foreign owners
have the same tangible capital structure as the industry average.

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FDI Data
European Stocks at the Top

Germany ranks seventh in the world as a recipient of foreign direct investment (FDI), according
to

the

United

Nations

Conference

on

Trade

and

Development

(UNCTAD).

According to official Bundesbank (German Central Bank) statistics for 2012, fifty-eight
percent (or EUR 346 billion) of all FDI stocks in Germany originate from within the EU-27, with
a further eight percent stemming from the remaining European non-EU countries.
Investments from outside the EU continue to grow. North America accounts for 24 percent of
FDI stock, while Asia holds a nine percent share. Especially Asian countries increased their FDI
stocks in Germany in recent years. Germany is the worlds largest recipient of new Chinese fdi
projects.

First Choice in Europe

A recent study conducted by the American Chamber of Commerce highlights the positive regard
in which the German business environment is held by US companies. Invited to indicate their
main medium-term investment focus within the EU, 29 percent of participating American
companies named Germany as their first choice followed by Eastern Europe (17 percent), and
Western Europe (12 percent) respectively.
The UNCTAD World Investment Prospects Survey 2013-2015 confirms Germany's reputation as
the most attractive business locations in continental Europe. 161 Trans-National Companies
ranked Germany first within Europe, and fifth internationally as top destination for 2013-2015.
The Ernst & Young study on the attractiveness of the European economic area (2014) also shows
that Germany is the number one business location in Europe and the number four worldwide.

Competitiveness Study

Germanys Rank in Germanys

Europe

Ernst & Young European Attractiveness Survey 1

Rank

Worldwide

(2014)

A.T. Kearney FDI Confidence Index (2014)

UNCTAD World Investment Prospects Survey 1

2013-2015 (2013)
High Scores in Infrastructure and Workforce
In the above mentioned Ernst & Young study, over 800 international decision-makers were surveyed on
Europe and a further 201 companies were asked questions with a specific focus on Germany.
Germany received many great marks for various business location factors. These include infrastructure
(telecommunications and transport), workforce qualifications and the social climate. 55 percent of those
surveyed predict that Germanys attractiveness will continue to grow in the coming years.
The study further shows that Germanys growth drivers are in the transportation and automotive
industries, environmental and energy technology, as well as the information and communication sector.

Surveyed managers expect that in the future most of the investments will go into research and
development as well as in manufacturing. It is no surprise that 64 percent of companies surveyed are
convinced that Germany is pursuing a policy that attracts international investors.

Ongoing Interest in Greenfield Investments

Between 2008 and 2013, fDi Markets recorded more than 4,700 investment projects in Germany
by some 3,900 foreign companies. With 857 greenfield projects, 2012 proved to be the most
successful year ever recorded, with Germany placing forth worldwide in terms of FDI projects

attracted. In 2013, nearly 800 projects were recorded, making it the third best result ever
achieved. FDI results are based on greenfield project announcements (including expansions and
joint ventures) collected in the Financial Times Group's fDi Markets database.
The most important countries as sources for new investment projects are the USA (24 percent of
all investment projects), Switzerland (eight percent), and UK (eight percent), respectively. The
ICT & software industry, and business & financial services are leading sectors in attracting new
projects. The industrial machinery & equipment, textiles, consumer goods, and chemical
industries are likewise attractive foreign investment sectors in Germany.
Most new projects open sales and marketing & support offices. One in seven investment project
is manufacturing-site located making this a very important business activity in Germany.

R&D Framework

German firms are global leaders in the development of

new technologies.
For over a century, the Made in Germany label has stood for innovation and excellent quality.
Exports of high-tech products in 2009 were worth a total of 102 billion euros. This makes
Germany the top exporter in Europe and the second largest in the world.
Strong Innovation Performance

Germany enjoys an excellent reputation regarding its dynamic and innovative R&D
environment. This is regularly confirmed by leading international comparisons on innovative
capability. The latest example can be found in the current Innovation Union Scoreboard (IUS),
which is used as an instrument by the European Commission for the evaluation of the innovative
performance of European nations. The IUS ranks Germany among the group of leading
innovators. Within the EU, only Sweden and Denmark are placed ahead of the German R&D
location. With its high innovation output, Germany is a first rate location for R&D projects.

The
'Innovation Index' is made up from a total of 25 indicators for the measurement of innovation.
Along with others, public and private R&D outlay, the education level, and the proportion of
patent grants at the international patent offices per million inhabitants are considered. The
Innovation Union Scoreboard (IUS) was developed in the scope of the Lisbon strategy and is an
instrument of the European Commission. Source: European Innovation Scoreboard (2013)
The unique innovative potential of Germany as a research location is also acknowledged by
international executives. According to a survey by Ernst & Young, a quarter of the decisionmakers asked, think Germany is the most attractive R&D location in the world, ahead of
neighbouring Switzerland as well as the USA.
A further expression of the 'world class performance' of German R&D departments is provided
by the results of the surveys by the American Chamber of Commerce in Germany (AmCham).

In these surveys 29 percent of the companies state that they are developing their R&D activities
in Germany. For this reason, they are increasingly establishing their own research and
development centres that are utilising R&D potentials with national as well as global
responsibilities.

Rising R&D Expenditure

In Germany, enormous sums of money are invested in the development of new technologies and
innovations. No other country in Europe invests greater sums in research and development
(R&D). Since 2000, Germany R&D expenditures have been continuously rising.
In 2012, public and private spending on research projects in Germany amounted to
approximately EUR 79.4 billion representing 2.98% of GDP. This share places fourth in
Europe, behind the Scandinavian countries (Finland, Sweden, Denmark), but significantly ahead
of France and the United Kingdom.
This means that Germany is well on track to achieving the 3 percent goal specified by the
European Union within the coming years. More than two thirds of the expenditure are accounted
for by research intensive private business.

Industry Potential
Investments in Research and Development
Germany's position as a high-tech country is no mere accident. Companies invest significant
sums in order to continually bring innovative products and services to the market. According to
the joint initiative of German industry for promoting science and humanities (Stifterverband),
economy-related research and development expenditure accounted for EUR 57.4 billion in 2009.
In the following, we present a selection of the relevant fields of research in Germany for
investors with ambitious R&D goals.

Data
refers to 2008 (as share of the manufacturing industry). Sectors are defined by industry
classification codes WZ 2003. Total R&D expenditures include internal and external
expenditures. Source: Stifterverband Wissenschaftsst

Economic Activity
Europe's Economic Hub

Germany is the largest market in Europe. It constitutes 21 percent of Europe's GDP (EU-28) and
is home to 16 percent of the total European Union (EU) population. The German economy is
both highly industrialized and diversified with equal focus placed on services and production.
GDP
(in

SHARE
EUR GDP

OF

TOTAL

POPULATION
(in m)

SHARE
POPULATION

tn)

(EU-28)

Germany

2.74

21%

81

16%

France

2.06

16%

66

13%

UK

1.90

14%

64

13%

Spain

1.02

8%

47

9%

Netherlands

0.63

5%

17

3%

Poland

0.39

3%

39

8%

0.15

1%

11

2%

Hungary

0.98

1%

10

2%

USA

12.65

316

Japan

3.69

128

EU-28

13.07

506

Eurozone

9.60

333

Czech
Republic

(EU-28)

OF

TOTAL

Key Driver: The Manufacturing Industry

Almost 10 percent of Europe's manufacturing companies are German. They generate 30 percent
of the EU's gross value added in manufacturing alone. In fact, they represent more than one fifth
of all of Germany's value added one of the highest shares in Europe. Increasingly more foreign
companies are placing their faith in Germany as an essential location for production sites and are
benefiting from the country's excellent business framework and superior productivity rates.

Market Reach
Germany's central location in the middle of Europe brings with it a closely tied infrastructure
network. All European capital cities can be quickly reached by land, air or water from Germany.
Relations with fellow EU member nations are particularly strong. Customs duty exemptions
within the EU allow free trade between the community's 28 member states. By the end of 2014,
eighteen member countries had introduced the euro as its common currency which has
eliminated exchange rate risks which would otherwise prove an obstruction to bilateral trade.
These close relationships are reflected in the significance of the EU as a foreign trade partner.
Nearly two thirds of all German imports and exports come from or remain within the EU.
Around three quarters of all foreign direct investments in Germany and more than half of all
German direct investments overseas originate from or are made in EU countries.

IMPORTS OF GOODS
Country of Origin

EUR bn

EXPORTS OF GOODS
Country of Destination

EUR bn

1 Netherlands

89.1

1 France

100.3

2 China

73.6

2 USA

88.4

3 France

64.1

3 UK

75.6

4 USA

48.5

4 Netherlands

70.9

5 Italy

47.5

5 China

67.0

6 UK

42.3

6 Austria

56.2

7 Russia

40.4

7Italy

53.3

8 Belgium

38.9

8 Switzerland

47.3

9 Switzerland

38.2

9 Poland

42.4

10 Austria

36.8

10 Belgium

42.3

Conclusions
In this paper we evaluate the German tax reform of 2000 with respect to its eect on inward
foreign direct investment. We deal with the identi.cation problem by re- ferring to the rather
radical assumption that the aggregate eect of the tax reform is equal to zero. Nevertheless, we
.nd signi.cant tax eects. The baseline regres- sion indicates that a reduction in the eective
marginal tax rate of 10 percentage points increases net investment by 1 percentage point. Given
an investment level of around 7,5% and a pre-reform EMTR of around 52%, the elasticity of
invest- ment with respect to eective marginal taxation is approximately equal to 0; 7.
In comparison to other empirical studies this estimate is rather at the bottom line, but it should be
recalled again that our results are based on an assumed aggregate eect of zero. We employed
two distinct approaches to measure the tax impact on inward FDI. The .rst de.nes the pre-reform
period (1997-1999) as the control group and the post-reform period (2001-2003) as the treatment
group. The second links periodical variations in the investment process to periodical variations in
the tax incentive scheme. Both approaches yield virtually the same results.
The data con.rm several predictions from standard tax theory. Pro.table .rms on average show a
strong and signi.cant tax impact while non-pro.table .rms do not. Firms with a high debt level are
less tax-sensitive than .rms with a high equity share. Tax considerations seem to be more relevant
in branches in which investment is likely to be cost-driven, like manufacturing, and less so in
wholesale trade activities and services, which are supposed to be complements to some foreign
production units. Geographic proximity plays a major role. We can show that the tax eect is
strong and signi.cant for European investors while American and Asian investments do not show

any tax eect. Among Europeans, the investors from countries with a common border with
Germany show the strongest tax-sensitivity.
Besides those expected results, our data give some new and interesting insights, which deserve
further testing and research. First, among the pro.table .rms, only the just-above-zero pro.table
.rms show a signi.cant tax eect. Under certain assumptions, this could be interpreted as hint
towards liquidity constraints. As a 26 matter of fact, the reduction of the eective tax burden
always has an income eect and - under the assumption of imperfect capital market - this may
induce .rms which are cash-.ow constrained to increase investment. Analyzing this question
thoroughly is beyond the scope of this paper, though, and would require better data. Second, .rms
with a high fraction of non-.nancial assets do react strongly to the tax reform while others do less
so. This is surprising because predictions derived by standard tax theory said that those .rms
would lose relative to others from the tax reform. Third, our data fail to show signi.cant
dierences between the marginal investment choice model and the discrete investment choice
model.
This may be due to the fact that our data sample is considerably reduced when we compare these
two models and that .rms with a higher pro.tability (i.e. those which are candidates to con.rm the
discrete investment choice model) do not show any tax impact. In addition, the two tax rate
measures under consideration are highly correlated, so we would not expect great dierences in
the coe cients or standard errors. The problem is that the tax rate cut is equal for all .rms, so we
lack an approach to identify the impact of this feature of the tax reform, given that we cleaned
the time series from any aggregate impact.