流动资本的倒置世界

发自伯克利——越来越多的美国公司都在通过收购外国企业的方式将自己的总部移到国外。最近的一个例子是美敦力(Medtronic)计划收购位于爱尔兰的科惠医疗(Covidien)——后者是一间从美国泰科国际公司(Tyco)剥离出来的规模极小的企业——从而将总部转移到税率较低的爱尔兰,并催生了有史以来总部与分支机构“倒置”或“再安置”现象最显著的美国企业。有报道称美国药品零售企业沃格灵斯(Walgreens)正在考虑借助收购位于瑞士的药业零售巨头联合博姿(Alliance Boots)的公开市场股份,进而将总部迁移到英国。

这些交易反映出美国企业税体系所存在的深层次缺陷。美国拥有发达国家中最为高昂的法定企业税率,也是七大工业国中唯一保留着早已过时的国际税收体系,要求美国企业海外利润回流本国时缴纳额外本地税项的国家。

相比之下,其他6个发达工业国都实施了“区域性”体系,只对本国跨国企业回流的国外利润征收极少甚至零税率。这一差别导致美国跨国企业的竞争力在国外地区相对别国竞争者处于劣势。为抵消这一劣势,美国跨国企业都会选择美国税法中的一个延期选项。

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