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Cost Structure and Tax-Motivated Income Shifting

McGuire, Sean T., Rane, Scott G., Weaver, Connie D.

The Accounting Review · 2023 · Volume 98 · Issue 7

DOI: 10.2308/TAR-2020-0190

Abstract

We examine whether cost structure influences tax-motivated income shifting. We predict and find that U.S. multinational corporations (MNCs) with a less rigid cost structure engage in greater levels of tax-motivated income shifting relative to MNCs with a more rigid cost structure. This result is consistent with a less rigid cost structure providing greater flexibility to enable MNCs to take advantage of income-shifting opportunities. Further, we find that this relation is more pronounced when firms face greater costs in adjusting their operations, have less transfer pricing flexibility, and operate in a more uncertain environment. These results suggest that firms with less rigid cost structures possess the strategic operating and accounting flexibility necessary to take advantage of income-shifting opportunities. We provide evidence suggesting that a firm’s cost structure, a fundamental attribute of a firm’s business model, is a distinct and incrementally important determinant of tax-motivated income shifting. Data Availability:All data used in this study are publicly available. JEL Classifications:G32; H26; M41.

Keywords

tax-motivated income shifting, cost structure, tax avoidance, international taxation

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