1、原文 ： Effects of Corporate Tax Reforms on SMEs Investment Decisions under the Particular Consideration of Inflation Corporate tax reforms carried out in EU countries since 1980 entail lower statutory tax rates and reductions in generous tax depreciation provisions. Several countries including the UK
2、have reduced tax rates for small and medium sized enterprises (SMEs). This study compares incentive effects of such reforms on the SMEs investment decisions adopting a simple present value model. Ceteris paribus, tax rates and depreciation rules vary in the model simulation, while the application of
3、 historical cost accounting method in inflationary phases leads to fictitious increases in nominal net present value. Apart from the construction of international ranking, country-specific patterns of reform effects are also illustrated. The vast majority of firms that operate in advanced countries
4、are small and medium-sized enterprises (SMEs). Therefore, SMEs competitiveness significantly affects the competitive position of a countrys economy as a whole. The concentration of SMEs activities on domestic market leads to a bounded business vision. Combined with the asymmetric information about p
5、rofit opportunities abroad, this fact tends to limit the diversification of SMEs investments in an international context. Consequently they appear to be more directly affected by the national corporate tax reform than is the case with large multinational firms. On the other hand, SMEs have quite oft
6、en been the primary target group of such an investment promotion policy (Chen et al., 2002； Devereux et al., 2004； Hendricks et al., 1997). According to Coyne (1995), SMEs are generally more responsive to domestic tax incentives than large ones. Taxes may play a more important role in the cost struc
7、ture of SMEs because they do not have the financial and human capacity to developed sophisticated tax avoidance strategies. Some EU countries including the UK have traditionally had lower tax rates for SMEs, whereas such a corporate tax reduction does not exist in countries like Austria, Finland and
8、 Germany at all. Although it is disputable, those countries that provide fiscal incentives and preferential tax treatment to SMEs claim that they (1) create a large number of jobs and (2) enhance the level of entrepreneurship, which implies flexibility, speed, risk-taking and innovation (Chen et al.
9、, 2002). A further reason for the tax policy attention paid to SMEs is that they represent an important breeding ground for large, profitable, tax-paying employers of the future and experience high growth rates in comparison to large enterprises (Hendrickset al., 1997, p. 1). According to Santarelli
10、 and Vivarelli (2002), however, those less-efficient SMEs tend to have a higher expected probability to exit from the market than larger firms do and for this reason it is optimal for them to invest more gradually in the course of time, since entry and other investment costs made at the setting-up p
11、hase are sunk. In this context a government subsidy may reduce differences between the efficient and the inefficient firms, and consequently disturb not only investment decisions but also market selection as well as the learning process undergone by entrepreneurs. The statutory corporate tax rate is
12、 clearly important in calculating the overall tax burden. However, this tax rate does not, in itself, establish the ultimate tax burden on a firms investment activity. Equally crucial are the effects of depreciation and other investment promotion provisions that determine the tax base (2004). In the
13、 practice of corporate tax policy different tax depreciation rules are employed that do not typically ensure the socalled true economic depreciation (Samuelson,1964； Sinn, 1987). Furthermore, their generosity has been extended to stimulate private investment. On the other hand, depreciation based up
14、on historical cost is undervalued during inflationary phases, as the real cost of depreciation of todays assets is underestimated when the asset base is measured in nominal terms (Cohen and Hasset, 1999； Haufler and Schjelderup,2000； Ott, 1984). There have been a number of attempts to estimate the c
15、urrent value of a capital good on the basis of indexation (Feldstein, 1979； Feldstein and Summers, 1979； Hulten and Wykoff, 1996). The research of the effective capital income tax rates based on the so-called user cost of capital approach received a significant stimulus from King and Fullerton (1984
16、). The follow-up studies in this area often suggested that the tax systems of most advanced economies were characterized by serious non-neutralities in the early and mid-1980s, . reflected in large differences in marginal effective tax rates on capital across different asset types, modes of finance,
17、 and investor groups, and their overall burden was quite high, in particular because of failure to adjust the nominal tax base for inflation. Triggered by the liberalization of international capital flows in the1980s, Alworth (1988) and Keen (1991) further developed the King-Fullerton approach origi
18、nally focussed on domestic investments financed by domestic savings to capture the aspect of taxing multinational companies. The studies made by Devereux together with Griffith and Klemm (including Devereux and Griffith, 1998, 2003； Devereux et al., 2002； Devereux, 2004) have made a decisive contrib
19、ution to the generalisation and expansion of the same approach for estimating average1 and marginal effective tax rates on domestic and foreign investment in the EU and OECD countries (European Commission, 2001； OECD, 1991). According to these international studies of effective tax rates, foreign in
20、vestment is likely to be overtaxed in relation to the domestic type due to incomplete alleviation of international double taxation. Yet an overestimation of the tax burden can emerge since the open-economy King Fullerton framework does not allow for all the important possibilities for tax planning a
21、vailable to multinational companies, which include taxation of royalties, use of tax havens for financing subsidiaries, allocation of parent interest expense to foreign income, shifting options for debt to high-tax foreign locations or the home country, etc. (Altshuler and Grubert, 2003； Grubert, 19
22、98, 2003, 2004； 2004). The effective (marginal and average) corporate tax rates are often defined as forward looking measures demonstrating the effect of tax on future expected earnings on a specific investment project. On the other hand, the calculation of average tax burden for example, in terms o
23、f a proportion of aggregate tax revenue to profit or a certain macroeconomic tax base like a measure of the operating surplus of the economy (Mendoza et al., 1994) is characterised to be backward-looking since it captures the impact of tax on the returns in any period of the whole past history of a firms investment decisions”(Devereux et al., 2002, p. 456). One reason for the low popularity of this method in the field of capital income taxation is that apart from corporate income taxes the aggregate tax revenue also includes, for instance, taxes on
