Managing the Multinational Financial System Shapiro: Chapter 16
Shapiro: Chapter 16 Problem 16.1
Multinational Financial System “... ability to shift funds and accounting profits among its various units ... through internal financial transfer mechanisms.”
Multinational Financial System “ … over 38% of U. S. imports and exports are transactions between U. S. firms and their foreign affiliates or parents.”
Two-way International Trade Parent to/from a foreign subsidiary: U. S. & Japan: 80% U. S. & Europe: 40% EC & Japan: 55%
Multinational Arbitrage Opportunities Tax arbitrage Financial market arbitrage Regulatory system arbitrage
Multinational Financial System [Advantages] Tax arbitrage: high-tax to low-tax nations taxpaying to tax-loss units Financial market arbitrage: circumvent exchange controls earn higher risk-adjusted returns reduce borrowing costs
Multinational Financial System [Advantages] Regulatory system arbitrage: disguise true profitability negotiating advantage Offset credit restraint or controls draw on external sources of funds
Tax Factors (Intercompany Transfers) Types of taxes (host country) corporate income taxes taxes on dividends, interest, and fee remittances taxes on retained earnings Foreign tax credit offsets U. S. taxes
MNC Financial Channels Transfer pricing Reinvoicing Centers Fees and royalties Leading and lagging Intercompany loans Dividends Equity vs. debt
Transfer Pricing Reduce taxes Unit A sells to Unit B: if tA > tB, low transfer price if tA < tB, high transfer price
Transfer Pricing [A sells to B]
Transfer Pricing [A sells to B]
Transfer Pricing [A sells to B]
Transfer Pricing [A sells to B]
Transfer Pricing [A sells to B]
Transfer Pricing Strategy Reduce taxes Reduce tariffs Avoid exchange controls Increase profits from joint ventures Disguise affiliate’s profitability
Fees and Royalties [International Transfers] Intangible factors of production headquarters services allocated overhead patents and trademarks IRC Section 482: “commensurate with the income” generated
Fees and Royalties [International Transfers] Allocate total fees according to sales or assets
Leading & Lagging Payments Accelerating or delaying payments Modifying credit terms Opportunity cost of funds: paying unit receiving unit interest rate differentials
Leading & Lagging Payments Advantages over direct loans: no formal note of indebtedness less government interference interest free for 6 months (Sec. 482)
Leading & Lagging Payments
Leading & Lagging Payments
Leading & Lagging Payments
Leading & Lagging Payments
Intercompany Loans (1) Transfer of funds through making and repaying of intercompany loans More valuable than arm’s-length transactions if the following exist: credit rationing currency controls differential tax rates
Intercompany Loans (2) Direct Loans Back-to-Back Financing Parallel Loans
Direct Loans Straight extension of credit From parent to affiliate From one affiliate to another No intermediary involved
Back-to-Back Loans (1) [Fronting loans; link financing] Used in countries with: high interest rates restricted capital markets currency controls different tax rates for loans from a financial institution
Back-to-Back Loans (2) Parent deposits funds with a bank in Country A Bank lends funds to subsidiary in Country B Effectively, an intercompany loan channeled through a bank
Back-to-Back Loans (3) Risk free for the bank - deposit collateralizes the loan Bank serves as intermediary Bank’s compensation is the difference between borrowing and lending rates
Structure of a Back-to-Back Loan Parent firm in Country A Subsidiary in Country B
Structure of a Back-to-Back Loan Parent firm in Country A Subsidiary in Country B Direct Loan
Structure of a Back-to-Back Loan Parent firm in Country A Subsidiary in Country B Direct Loan Deposit Bank in Country A
Structure of a Back-to-Back Loan Parent firm in Country A Subsidiary in Country B Direct Loan Deposit Back-to-Back Loan Bank in Country A
Structure of a Back-to-Back Loan Parent firm in Country A Subsidiary in Country B Direct Loan Deposit Back-to-Back Loan Bank in Country A
Parallel Loans Two related but separate borrowings Usually involves four parties Two separate countries Bank fees: 0.25%-0.50% of principal
Dividends Most important transfer mechanism Over 50% of remittances to USA Parent’s dividend payout ratio (D/E) Other factors: tax effects financing requirements exchange controls
Equity vs. Debt? MNCs generally prefer loans to equity Easier to repatriate interest and principal than dividends and equity Tax benefits of debt: interest deductible in host country loan repayments not taxable to parent
Designing a Global Policy How much money to remit? When to remit? Where to transmit funds? Which transfer method to use? Satisfactory vs. optimal decisions
Shapiro: Problem 16-1 a. 1,500 (27,000 - P) (.45 - .50) P = $30,000 maximizes tax savings b. 1,500 (27,000 - P)[.45+.15-.50(1.15)] = 1,500 (27,000 - P) (.025) P = $25,000 maximizes tax savings
Shapiro: Problem 16-1 c. $27,000 X 1.05 = $28,350 1,500 (27,000 - 28,350) (.45 - .50) = $101,250 (decline in tax) 1,500 (28,350-27,000)[.45+.15-.5(1.15)] = $50,625