210 likes | 219 Views
Explore the value of financial systems, intercompany fund-flow mechanisms, and global remittance policy design in multinational finance. Learn about tax, market, and regulatory arbitrage, transfer pricing, intercompany loans, and more.
E N D
Multinational Financial ManagementAlan Shapiro7th EditionJ.Wiley & Sons Power Points by Joseph F. Greco, Ph.D. California State University, Fullerton
CHAPTER 20 MANAGING THE MULTINATIONAL FINANCIAL SYSTEM
CHAPTER 0VERVIEW I. THE VALUE OF THE MULTINATIONAL FINANCIAL SYSTEM II. INTERCOMPANY FUND-FLOW MECHANISMS: COSTS AND BENEFITS III.DESIGNING A GLOBAL REMITTANCE POLICY
I. THE VALUE OF THE MULTINATIONAL FINANCIAL SYSTEM I. THE MNC’s DISTINCT VALUE A. Allows MNC to arbitrage 1. Tax systems 2. Financial markets 3. Regulatory systems
THE VALUE OF THE MULTINATIONAL FINANCIAL SYSTEM A. Tax Arbitrage 1. Wide variations exist in global tax systems 2. Firms reduce taxes paid -move funds to low-tax jurisdiction
THE VALUE OF THE MULTINATIONAL FINANCIAL SYSTEM B. Financial Market Arbitrage 1. Assume imperfect markets because a. Formal barriers to trade exist b. Informal also exist c. Imperfections in domestic capital markets exist.
THE VALUE OF THE MULTINATIONAL FINANCIAL SYSTEM C. Regulatory Arbitrage 1. Arises when subsidiary profits vary due to local regulations. 2. Example: a. Government price controls b. Union wage pressures, etc. 3. Firms may disguise true profits in order to gain better negotiations
II. INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS II. INTERCOMPANY FUND-FLOW MECHANISMS A. MNC Policy: Unbundling breaks up a total international transfer of funds between pairs of affiliates into separate components. B. Example: Headquarters breaks down charges for corporate overhead by affiliate.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS C. Inter-company Fund Flows 1. Tax Factors: a. Taxes available on 1.) corporate income 2.) personal income (includes dividends) b. U.S. Tax System tax income remitted abroad on corporate income tax.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS c. Offset: Foreign tax credit given on income already tax. 2. Transfer Pricing a. Definition: pricing internally- traded goods for the purpose of moving profits to a more tax-friendly nation.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS b. Uses of Transfer Pricing 1.) Reduces taxes paid 2.) Reduces ad valorem tax 3.) Avoids exchange controls
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS 3. Reinvoicing Centers a. Set up in low-tax nations. b. Center takes title to all gods. c. Center pays seller/paid by buyer all within the MNC. d. Advantages: 1.) Easier currency changing 2.) Other invoice currency, other than local, available.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS e. Disadvantages of Reinvoicing 1.) Increased communications costs 2.) Suspicion of tax evasion by local governments. 4. Fees and Royalties a. Firms have control of payment amounts. b. Host governments less suspicious.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS 5. Leading and Lagging a. Highly favored by MNCs b. Value depends on opportunity cost c. No need for formal debt d. Less chance of local government suspicion.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS 6. Intercompany Loans a. Useful when following present: 1.) Credit rationing 2.) Currency controls 3.) Differential tax rates
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS b. Types of Inter-company Loans 1.) Back-to-back loans a. ) Often called fronting loan b. ) Loan channeled through a bank c. ) Loans collateralized by parent deposit.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS c.) Advantages (1.) protects against confiscation (2.) reduces taxes (3.) accesses blocked funds 2.) Parallel loans a.) Consists of 2 related but separate loans with 4 parties in 2 nations.
INTERCOMPANY FUND-FLOWMECHANISMS: COSTS AND BENEFITS b.) Purpose of parallel loan (1.) repatriate blocked funds (2.) avoid currency controls (3.) reduce currency exposure 7. Dividends most important method of transferring funds to parents
III. DESIGNING A GLOBAL REMITTANCE POLICY III. DESIGNING A GLOBAL REMITTANCE POLICY A. Factors: 1. Number of financial links 2. Volume of transactions 3. Ownership patterns 4. Product standardization 5. Government regulations
DESIGNING A GLOBAL REMITTANCE POLICY B. Information Requirements of a Global Remittance Policy -firm needs following details 1. Subsidiary financing requirements 2. Sources/costs of external capital 3. Local investment yields 4. Financial channels available
DESIGNING A GLOBAL REMITTANCE POLICY B. Information Requirements (con’t) 5. Transaction volume 6. Relevant tax factors 7. Government restrictions on transfer of funds.