| 冯晨,周小昶,曹源圆.税收情报交换与跨国公司策略重构[J].数量经济技术经济研究,2026,(7):82-106 | | 税收情报交换与跨国公司策略重构 | | Tax Information Exchange and Multinational Firm Strategies Restructuring | | | | DOI： | | 中文关键词: 反避税 税收情报交换协定 集团公司 | | 英文关键词: Anti-tax Avoidance TIEA Multinational Company | | 基金项目:反避税；税收情报交换协定；集团公司 | | | 中文摘要: | | 中国积极参与的全球反避税政策行动对于抑制跨国公司利润转移与海外避税等离岸活动发挥了重要作用，在此背景下，跨国公司新型避税手段成为税务部门亟需关注的重点问题。本文基于独特的跨国集团网络数据，实证检验了在税收情报交换协定为代表的反避税政策背景下，跨国集团的避税策略选择。研究发现，交换协定对跨国集团的海外利润转移与避税行为发挥了抑制作用，但跨国集团会在国内从事相应的避税替代活动，采取向国内子公司进行利润转移与账户操纵等方式释放税负。从估算规模来看，反避税政策在总体上发挥了明显作用，而集团采取的避税替代活动造成了真实政策效应的效率损失。本文研究为有效识别反避税政策效果，大力推进境内反避税政策的设计与出台提供了崭新思路。 | | 英文摘要: | | The widespread existence of tax havens has become a major constraint on national fiscal capacity, as they exacerbate tax base erosion, facilitate tax revenue leakage, and reduce public revenues, thereby providing multinational companies (MNCs) with direct channels for tax avoidance. Since 2006, the Chinese government has actively participated in global anti-tax avoidance initiatives. At various G20 summits, President Xi Jinping has repeatedly emphasized the need to strengthen global tax cooperation, combat international tax evasion and avoidance, and advance international tax fairness. In this context, China has signed a Tax Information Exchange Agreement (TIEA) with several countries and regions, committing under international treaties to exchange tax information and share regulatory resources. As a key instrument to detect offshore tax avoidance, the TIEA has become an effective tool to address cross-border tax avoidance and has played an important role in curbing MNCs’ offshore tax avoidance. Nevertheless, an open question remains: do MNCs respond by adopting a “tax avoidance reshoring” strategy, shifting the avoidance activities previously conducted in tax havens toward low-tax jurisdictions within China?
Using a hand-collected dataset on multinational business groups from 2007 to 2016 and employing a Difference-in-Differences (DID) design, this study evaluates the effectiveness of anti-tax avoidance policies and MNCs incentives for tax-avoidance substitution. The four main findings of this study are as follows.First, while the signing of the TIEA significantly curbed MNCs’ offshore tax avoidance, the tax avoidance by their domestically controlled subsidiaries also significantly increases. Second, the results of the mechanism analyses suggest that after the signature of the TIEA, the incentives for profit shifting and earnings manipulation between parent firms and domestic subsidiaries have intensified, helping reduce the likelihood of tax scrutiny. Third, the response to the TIEA has been more pronounced among firms facing tighter financing constraints; firms located in jurisdictions with weaker tax enforcement, and subsidiaries operating in industries with more salient tax preferences, relative to firms with looser financing constraints; firms in regions with stronger tax enforcement; and subsidiaries in industries with less pronounced tax preferences. Fourth, we estimated the policy’s net effect and found that the TIEA substantially mitigated tax base erosion, preventing tax revenue losses from offshore avoidance amounting to RMB 2.67 billion; however, the substitution toward domestic avoidance has eroded the overall policy effectiveness by approximately 60%.
This study contributes to the existing literature in three respects. First, by adopting a group-level perspective, we examined the interlinked effects of domestic and offshore tax-avoidance strategies. This approach allows to obtain a clearer characterization of the instruments and channels through which business groups engage in tax avoidance and profit shifting, as well as the functional role of intra-group related-party markets. In contrast, prior research mainly focused on tax avoidance at the level of individual firms, an approach that not only risks to substantially underestimate the scale of avoidance, but also limits our ability to identify the specific mechanisms employed by large groups. Second, by conceptualizing firms as embedded in corporate networks, we provide a more comprehensive understanding of the way in which tax enforcement policies operate, and extend existing research to consider the true policy effects and welfare implications of tax administration. Existing studies on tax enforcement often treated firms as independent, static entities, and mainly assessed the average impacts on effective tax burden or avoidance, overlooking the strategic interactions within related-party networks and the cross-regional spillovers that arise when firms seek to offset their tax burden. These omissions may lead to an overestimation of the effectiveness of tax enforcement policies. Third, we assembled a novel parent-subsidiary dataset for Chinese business groups through manual collection and merging, and leveraged equity-network characteristics to capture intra-group operational linkages and financial information flows. This provides technical support to open the “black box” of internal group operations and to investigate a range of within-group behaviors, while also complementing and extending existing efforts to construct network-based databases on business groups.
This study offers new insights for the effective identification of the impacts of anti-tax avoidance policies, and provides a fresh perspective to advance the design and introduction of domestic anti-tax avoidance policies in China. | | 查看全文 相关附件： 下载数据代码附录 |
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