Tax Reforms by Timing Effects or Tax Rate Effects? Analyzing the Example of the German Reduced Repatriation Tax for Partnerships

Abstract

This paper analyzes two typical effects of tax reforms, tax rate effects and timing effects. The example chosen for the analysis is the tax privilege for retained profits of partnerships and sole proprietorships, which was implemented in Germany in 2008. Taking equity-financing and top marginal tax rates into account, the so-called tax privilege turns out to be a disadvantage under most assumptions. If the alternative investment is private capital income taxed at a flat-rate tax, the tax privilege will always be disadvantageous. If profits have to be retained and business income is the alternative investment, then the tax privilege will be advantageous in case of high income tax rates and interest rates. Analyzing progressive tax rates instead of top marginal tax rates reveals favorable results in case of fluctuating profits if the tax privilege is claimed. The same is true if debt-financing is taken into account. All in all, the paper shows that a reform of tax rates influences the attractiveness of investments much more compared to timing effects.