국내 외국인 투자기업의 국가 간 소득이전에 관한 연구

This study examines cross-jurisdictional income shifting by foreign-controlled firms in Korea. Specifically, we examine whether and how the difference in the statutory tax rates between foreign countries and Korea influences the inbound and/or outbound income-shifting behavior of foreign-controlled firms. We expect that firms owned by low-tax (high-tax) countries have incentives to shift income out of (into) Korea, thereby maximizing their worldwide after-tax income. Using 21,115 firm-year observations of foreign-controlled firms in Korea from 2006 to 2020, we find that the extent of income shifting increases with the tax incentives. In particular, the income-shifting behavior is asymmetric in that we observe outbound-income shifting by firms owned by low-tax countries but not inbound-income shifting by those owned by high-tax countries. We also provide evidence that the tax-motivated income shifting of foreign-controlled firms has increased during the sample period. Finally, we find that the tax-motivated income shifting is more pronounced for firms with high discretionary expenses and those with more related-party transactions, whereas it is less pronounced for those with high growth opportunities. The results are consistent with the notion that the extent of tax-motivated income shifting varies depending on the flexibility of income shifting strategy and the non-tax cost of future investment opportunities. Overall, our study sheds light on the tax-motivated income shifting of foreign-controlled firms and offers important implications for tax authorities and policymakers who try to limit tax avoidance by multinational corporations.