发展中国家吸引FDI税收政策的变化（发）.pdf

The Changing Structure of Tax Policies for Foreign Direct Investment in Developing Countries Jack M. Mintz ∗ 1. Introduction Developing countries keen to attract foreign direct investment (FDI) have typically used various preferential tax policies to be competitive. Tax holidays have been especially prevalent in the 1980s (Mintz [1990] and Shah [1995]) since they provide new foreign investors a low-tax regime for a qualifying period on the presumption that a company needs time to establish good levels of profitability. With increased globalization, many developing countries have been incorporating new tax policies for multinationals to establish headquarter, financial and trading operations in their jurisdictions. To attract FDI, while preserving revenue by countering efforts by multinationals to shift profits from high to low tax jurisdictions, many ∗ Deloitte Touche Professor of Taxation, J. L. Rotman School of Management, University of Toronto and President and CEO, C. D. Howe Institute, Toronto. Address for correspondence: C. D. Howe Institute, 125 Adelaide Street East, Toronto, M5C 1L7. 1 2 International Studies Program Public Finance Conference The Challenges of Tax Reform in a Global Economy countries have chosen low corporate income tax rates, low or no withholding taxes on income payments to non-residents, or low rates applied to income earned by holding companies. These policies seem to have become common in the past ten years compared to traditional tax holidays incentives. Picking the top 15 developing countries in terms of the FDI as a proportion of GDP for