
Chapter 8: International investment and financing decisions
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This leaves 880,000 dinars after tax, but if it wants to remit as much as possible to
the parent company and pays withholding tax of 10%, the parent company will only
receive × 100/110 of the available profits after tax (gross distribution). The parent
will receive 800,000 dinars and withholding tax will be (10%) 80,000 dinars.
The parent will exchange the dinars into $800,000 and it has paid tax at the effective
rate of 20% on its foreign subsidiary’s profits. The tax rate in the parent company’s
country is 25% on world-wide profits, so tax on $1,000,000 will be $250,000.
However, since tax of 250,000 dinars ($250,000) has already been paid in the
subsidiary’s country, and a double taxation agreement exists, the parent company
must pay $50,000 in extra tax to its domestic tax authorities.
Note. If the rate of tax had been lower in the parent company’s country, say 18%
rather than 25%, the subsidiary would pay profits on tax of 120,000 dinars and
withholding tax of 80,000 dinars, but no further additional tax would be payable by
the company to its domestic tax authorities.
The net effect is for the total amount of tax payable to be equivalent to tax at the
higher rate of the two countries concerned.
1.6 Fiscal risk
Fiscal risk is the risk that after a capital investment project has been implemented,
the government might increase the rate of tax payable on the profits or cash flows
from the project. Higher tax payments could significantly affect the returns from a
project.
Fiscal risk varies between countries. Some countries have a reputation for fiscal
stability, so that any changes in tax are fairly insignificant. In other countries there is
a much higher risk of tax changes. Obviously, companies considering an investment
in a country, even their domestic country, should take fiscal risk into consideration
when deciding whether or not to invest in a project.
Example
The oil and natural gas industry is an example of an industry where fiscal risk has
had a significant impact on capital expenditure decisions.
Oil companies purchase concessions to explore for oil or gas, and extract any that
they find. If they fail to find any oil or gas, they will lose their investment. However,
they face a risk that if they are successful in finding and extracting oil, the
government will decide to tax their profits. One way of doing this is to charge a
windfall tax on the profits of firms in the industry that operate in the country.
In the past the UK government has charged a windfall tax on the profits of
companies in the North Sea oil business. The matter was debated in Parliament in
2002, where it was claimed that if the government raised the rate of tax on the
profits of offshore oil and gas extraction to 40% or 50%, further exploration by the
oil companies would cease to be viable.