Shift happens: A comparison of the tax-motivated income shifting of multinationals in territorial and worldwide countries

This paper tests for differences in the tax-motivated income shifting behaviors of multinationals subject to different systems of taxing foreign earnings. I find that multinationals subject to territorial tax regimes shift more income than those subject to worldwide tax regimes, but that the difference in shifting is not statistically different when the worldwide firms can defer repatriation of the shifted income. I also find that the difference in shifting is greater when the multinational is cash-constrained in its home country. In additional tests, I find that worldwide firms bear the dead-weight cost of having cash trapped in foreign subsidiaries while territorial firms do not.