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Unit 3 - MNC Investment - Analysis
Unit 3 - MNC Investment - Analysis
International Tax
Planning
SINGAPORE | HONGKONG
20 YEARS IN PRACTICE
IYER PRACTICE Introduction to International Tax Planning
AGENDA
1. Background
4. Allocation of Taxing
Rights
6. Other Matters
7. Transfer Pricing
SINGAPORE | HONGKONG
20 YEARS IN PRACTICE
IYER PRACTICE Introduction to International Tax Planning
BACKGROUND
What is International Tax?
Inv
State A
100%
State B
State C
X
Who has the right to tax the dividend and service income?
? Tax Treaties
? EU tax law
• Avoidance
• Planning
• “Anyone may arrange his affairs so that his taxes shall be as low as
possible; he is not bound to choose that pattern which best pays the
Treasury. There is not even a patriotic duty to increase one’s taxes. Over
and over again the courts have said that there is nothing sinister in so
arranging affairs as to keep taxes as low as possible. Everyone does it,
rich and poor alike and all do right, for nobody owes any public duty to
pay more than the law demands”.
8
The Source Rule:
Primary Taxing Rights
Residence State
Income
Source State
Withholding
Activity
Residence State
Activity
• Company - a. Incorporation
13
Allocation of Taxing rights
• Multiple states may have a right to tax
• Taxing rights are allocated between the residence and the source state
R Co.
Activity Activity
15
Residence (Art. 1, 4)
• For a tax treaty to apply, entity must be
– Incorporation?
State R State S
R Co. PE
State R State S
R Co. Agent
State R State S
R Co. Service PE
• Beneficial Ownership
? Limitation of Benefits
Tax Treaty –
restricts S state
withholding tax
• Anti Abuse –
? Limitation of Benefits
R State
? Excessive Interest
• Key: definition
Tax Treaty –
restricts S state
withholding tax
• Beneficial Ownership
? Limitation of Benefits
Tax Treaty –
restricts S state
withholding tax
S
Tax Treaty –
restricts S taxation
R State
28
Other Matters
OTHER MATTERS
• New Rules (Hybrid entities)
OTHER MATTERS
• New Rules
? Treaty shopping?
? ALP still OK
• Increased Transparency
OTHER MATTERS
• Identifies key areas where there are concerns in the international tax
system
? General actions
? Treaty actions
• BEPS – Thoughts
OTHER MATTERS
• Exchange of Information under bi-lateral treaties (Art. 26 of OECD
MC)
• US’s FATCA
OTHER MATTERS
• Broad rule to catch what the law cannot
• Main purpose or one of the main purposes to obtain tax benefit etc.
OTHER MATTERS
• India Singapore Tax Treaty – Art 24 – Limitation of Relief
OTHER MATTERS
• Conduit Foreign Company Rules
OTHER MATTERS
• LOB clause is an anti-abuse provision which sets out which residents
of contracting states are entitled to treaty benefits
OTHER MATTERS
• Prevents potential stripping of income by limiting interest deductions
on debt owed to affiliates
• The company has high loans and hence pays more interest; or
38
Transfer Pricing
• Provides the methodology of
how prices should be charged
between related parties;
Interest R
• Not just the structures but the funding
underlying transactions may also
be scrutinized
TRANSFER PRICING
• Comparable Uncontrolled Price Method – compares the price charged for
properties or services transferred in a related party party transaction to the
price charged in an independent transaction in comparable situation
• Resale Price Method – used when products that has been purchased from a
related party is resold to an independent party. Resale price margin arrived
at to arrive at the ALP.
• Transactional Net Margin Method – compares the profit arising from related
party transactions with that generated from transaction with independent
parties.
• Profit Split Method – used when transactions are highly inter-related and
cannot be evaluated separately. Identifies the profit to be split and then
splitting the same based on the contribution of each party involved.
© OECD 2002
Summary and Conclusions
The report does not focus solely on the positive effects … while also taking
of FDI for development. It also addresses concerns about stock of the possible
potential drawbacks for host economies, economic as well costs and proposing
as non-economic. While many of the drawbacks, referred to ways to reduce
as “costs” in this report, arguably reflect shortcomings in them. 5
© OECD 2002
Foreign Direct Investment for Development: Overview
I. Trends
FDI hit new records The magnitude of FDI flows continued to set records
in 1999 and 2000… through the last decade, before falling back in 2001.
In 2000, world total inflows reached 1.3 trillion US dollars
WORLD 61 277 235 836 335 194 1 068 786 100 100 100 100
of which:
OECD countries 42 055 189 166 263 716 904 349 68.6 80.2 79.7 84.6
Non-OECD countries 19 222 46 670 71 437 137 747 31.4 19.8 21.3 12.9
of which:
Africa 404 195 3 100 7 267 0.7 0.1 0.9 0.7
Asia* 2 171 12 650 25 106 29 494 3.5 5.4 7.5 2.8
Europe* 8 408 3 570 14 026 0.0 0.2 1.1 1.3
Latin America
and Caribbean* 9 101 18 948 23 632 68 374 14.9 8.0 7.1 6.4
Near and Middle
East 212 1 056 1 936 1 571 0.3 0.4 0.6 0.1
Unallocated 7 325 13 413 14 093 17 015 12.0 5.7 4.2 1.6
* Excluding OECD countries.
Source: OECD International Direct Investment Statistics.
6
© OECD 2002
Summary and Conclusions
The limited share of FDI that goes to developing coun- … and although
tries is spread very unevenly, with two-thirds of total FDI developed countries
flows from OECD members to non-OECD countries going to were the main
Asia and Latin America. Within regions there are some recipients,
strong concentrations on a few countries, such as China and developing
Singapore in the case of Asia. Even so, FDI inflows represent countries also
significant sums for many developing countries, several of received
them recording levels of FDI, relative to the size of the domes- economically
tic economy, that overshadow the largest OECD economies significant sums…
(Figure 1). Moreover, the flow of FDI to developing countries
worldwide currently overshadows official development
assistance by a wide margin, further highlighting the need
to address the use of FDI as a tool for economic develop-
ment. The African continent’s apparent problem with
attracting FDI is briefly discussed in Box 1.
Developing countries
Developed countries
World
Africa
Latin America
Asia
North America
Western Europe
0 5 10 15 20 25 30 35
Per cent
Source: UNCTAD. 7
© OECD 2002
Foreign Direct Investment for Development: Overview
The entire African continent (except South Africa) received FDI inflows worth
an estimated US$ 8.2 billion in 2000. For comparison, this equals the amount of
inward FDI attracted by Finland this year, and it represented a mere 0.6 per cent
of total world FDI flows. Several recent studies have discussed the possible rea-
sons for this seemingly spectacular failure of African countries at attracting foreign
investors.
The main factors motivating FDI into Africa in recent decades appear to have
been the availability of natural resources in the host countries (e.g. investment in
the oil industries of Nigeria and Angola) and, to a lesser extent, the size of the
domestic economy. The reasons for the lacklustre FDI in most other African coun-
tries are most likely the same factors that have contributed to a generally low rate
of private investment to GDP across the continent. Studies have attributed this to
the fact that, while gross returns on investment can be very high in Africa, the
effect is more than counterbalanced by high taxes and a significant risk of capi-
tal losses. As for the risk factors, analysts now agree that three of them may be
particularly pertinent: macroeconomic instability; loss of assets due to non-
enforceability of contracts; and physical destruction caused by armed con-
flicts.1 The second of these may be particularly discouraging to investors domi-
ciled abroad, since they are generally excluded from the informal networks of
agreements and enforcement that develop in the absence of a transparent
judicial system.
Several other factors holding back FDI have been proposed in recent studies,
notably the perceived sustainability of national economic policies, poor quality of
public services and closed trade regimes.2 Even where the obstacles to FDI do not
seem insurmountable, investors may have powerful incentives to adopt a wait-
and-see attitude. FDI (and especially greenfield investment) contains an impor-
tant irreversible element, so where investors’ risk perception is heightened the
inducement would have to be massive to make them undertake FDI as opposed
to deferring their decision.3 This problem is compounded where a deficit of
democracy, or of other kinds of political legitimacy, makes the system of gov-
ernment prone to sudden changes. Finally, a lack of effective regional trade
integration efforts has been singled out as a factor.4 Due to this, national mar-
kets remained small and grew at a modest pace (and, in some cases, they even
contracted).
A few countries have, however, been able to attract FDI, apparently by virtue
of the quality of their domestic business climates. It has been argued that coun-
tries such as Mozambique, Namibia, Senegal and Mali in the late 1990s became
perceived as having a relatively benign investment environment.5 This seems to
have resulted primarily from government policies toward trade liberalisation; the
launch of privatisation programmes; modernising investment codes and adopting
international FDI agreements; developing a few priority projects of wider eco-
nomic impact; and, finally, engaging in high-profile publicity efforts, aimed at
informing investors of these improvements.
© OECD 2002
Summary and Conclusions
© OECD 2002
Foreign Direct Investment for Development: Overview
© OECD 2002
Summary and Conclusions
Average of inward and outward FDI Average of inward and outward FDI
relative to GDP (1995-2000) relative to GDP (1995-2000)
9 9
8 8
Sweden BLEU
Netherlands
7 7
6 6
UK
5 5
Switzerland
4 4
Canada
3 3
France
Germany
2 2
Spain
US
Australia
1 1
Korea
Japan Italy
0 0
0 10 20 30 40 50 60 70
Average of export and import relative to GDP (1995-2000)
Source: OECD International Direct Investment Statistics and OECD Economic Outlook. 11
© OECD 2002
Foreign Direct Investment for Development: Overview
The ability of FDI Host countries’ ability to use FDI as a means to increase
to contribute exports in the short and medium term depends on the con-
to developing export text. The clearest examples of FDI boosting exports are found
capabilities depends where inward investment helps host countries that had been
on context. Export- financially constrained make use either of their resource
processing zones endowment (e.g. foreign investment in mineral extraction) or
may be a tool for their geographical location (e.g. investment in some transition
closer integration economies). Targeted measures to harness the benefits of FDI
into world trade, but for integrating host economies more closely into international
they come at a cost. trade flows, notably by establishing export-processing zones
(EPZs), have attracted increasing attention. In many cases
they have contributed to a raising of imports as well as
exports of developing countries. However, it is not clear
whether the benefits to the domestic economy justify
drawbacks such as the cost to the public purse of main-
taining EPZs or the risks of creating an uneven playing
field between domestic and foreign enterprises and of
triggering international bidding wars.
FDI has generally Recent studies do not support the presumption that
not been an lesser developed countries may use inward FDI as a substi-
appropriate tool for tute for imports. Rather, FDI tends to lead to an upsurge in
import-substitution imports, which is often gradually reduced as local compa-
strategies. nies acquire the skills to serve as subcontractors to the
entrant MNEs.
b) Technology transfers
© OECD 2002
Summary and Conclusions
Technology transfer and diffusion work via four interre- Technology transfers
lated channels: vertical linkages with suppliers or purchas- are an important
e rs in th e h o st co u n tr ie s; h o riz o nt al l in ka ge s w ith aspect of MNE
competing or complementary companies in the same presence,
industry; migration of skilled labour; and the internationali- particularly through
sation of R&D. The evidence of positive spillovers is stron- vertical linkages…
gest and most consistent in the case of vertical linkages, in
particular, the “backward” linkages with local suppliers in
developing countries. MNEs generally are found to pro-
vide technical assistance, training and other information
to raise the quality of the suppliers’ products. Many MNEs
assist local suppliers in purchasing raw materials and
intermediate goods and in modernising or upgrading pro-
duction facilities.
© OECD 2002
Foreign Direct Investment for Development: Overview
… and basic labour Among the other important elements of the enabling
market standards environment are the host country’s labour market stan-
should be respected. dards. By taking steps against discrimination and abuse,
the authorities bolster employees’ op portunities to
upgrade their human capital, and strengthen their incen-
tives for doing so. Also, a labour market where participants
have access to a certain degree of security and social
acceptance lends itself more readily to the flexibility that is
key to the success of economic strategies based on human
capital. It provides an environment in which MNEs based in
OECD countries can more easily operate, applying their
home country standards and contributing to human capital
14 development. One strategy to further this goal is a wider
© OECD 2002
Summary and Conclusions
While the benefits of MNE presence for human capital Generic education
enhancement are commonly accepted, it is equally clear in the host economy
that their magnitude is significantly smaller than that of remains essential.
general (public) education. The beneficial effects of training Human capital
provided by FDI can supplement, but not replace, a enhancement
generic increase in skill levels. The presence of MNEs may, via foreign
however, provide a useful demonstration effect, as the subsidiaries may
demand for skilled labour by these enterprises provides provide a useful
host-country authorities with an early indication of what supplement…
skills are in demand. The challenge for the authorities is to
meet this demand in a timely manner while providing edu-
cation that is of such general usefulness that it does not
implicitly favour specific enterprises.
d) Competition
FDI and the presence of MNEs may exert a significant influence
on competition in host-country markets. However, since there is no 15
© OECD 2002
Foreign Direct Investment for Development: Overview
… not least among Empirical studies suggest that the effect of FDI on
developing host-country concentration is, if anything, stronger in devel-
countries… oping countries than in more mature economies. This could
raise the concern that MNE entry into less-developed coun-
tries can be anti-competitive. Moreover, while ample evi-
dence shows MNE entry raising productivity levels among
host-country incumbents in developed countries, the evi-
dence from developing countries is weaker. Where such spill-
overs are found, the magnitude and dispersion of their effects
are linked positively to prevailing levels of competition.
© OECD 2002
Summary and Conclusions
e) Enterprise development
FDI has the potential significantly to spur enterprise development
in host countries. The direct impact on the targeted enterprise includes
the achievement of synergies within the acquiring MNE, efforts to raise
efficiency and reduce costs in the targeted enterprise, and the develop-
ment of new activities. In addition, efficiency gains may occur in unre-
lated enterprises through demonstration effects and other spillovers
akin to those that lead to technology and human capital spillovers.
Available evidence points to a significant improvement in economic effi-
ciency in enterprises acquired by MNEs, albeit to degrees that vary by
country and sector. The strongest evidence of improvement is found in
industries with economies of scale. Here, the submersion of an individ-
ual enterprise into a larger corporate entity generally gives rise to
important efficiency gains.
17
© OECD 2002
Foreign Direct Investment for Development: Overview
© OECD 2002
Summary and Conclusions
© OECD 2002
Foreign Direct Investment for Development: Overview
There is little Empirical studies have found little support for the
evidence of MNEs assertion that policy makers’ efforts to attract FDI may lead
inducing host to “pollution havens” or a “race to the bottom”. The possi-
countries to loosen bility of a “regulatory chill”, however, is harder to refute for
their environmental the lack of a counterfactual scenario. Apparently, the cost of
standards. environmental compliance is so limited (and the cost to a
firm’s reputation of being seen to try to avoid them so
great) that most MNEs allocate production to developing
countries regardless of these countries’ environmental reg-
ulations. The evidence supporting this argument seems to
depend on the wealth and the degree of environmental
concern in the MNEs’ other countries of operation.
FDI may help address Empirical evidence of the social consequences of FDI
social concerns is far from abundant. Overall, however, it supports the
by acting as a tool to notion that foreign investment may help reduce poverty
alleviate poverty… and improve social conditions (see also Figure 3). The general
Share of population living below 1 USD per day Share of population living below 1 USD per day
80 80
70 70
60 60
50 50
40 40
30 30
20 20
10 10
0 0
0 5 10 15 20 25 30 35 40 45 50
FDI stock as percentage of GDP, 1995
© OECD 2002
Summary and Conclusions
The net benefits from FDI do not accrue automatically, The magnitude
and their magnitude differs according to host country and of the benefits from
context. The factors that hold back the full benefits of FDI in FDI depends on
some developing countries include the level of general edu- the efforts of host
cation and health, the technological level of host-country countries to put
enterprises, insufficient openness to trade, weak competition in place
and inadequate regulatory frameworks. Conversely, a level the appropriate
of technological, educational and infrastructure achieve- frameworks…
ment in a developing country does, other things being
equal, equip it better to benefit from a foreign presence in
its markets. 21
© OECD 2002
Foreign Direct Investment for Development: Overview
22
© OECD 2002
Summary and Conclusions
In cases where domestic legal, competition and envi- FDI tends to act
ronmental frameworks are weak or weakly enforced, the as a catalyst for
presence of financially strong foreign enterprises may not underlying strengths
be sufficient to assist economic development – although and weaknesses
there are examples (notably in finance) where the entry of in the host economy,
MNEs based in OECD member countries has contributed to bringing to the fore
an upgrading of industry standards. Where economic and both its advantages
legal structures create a healthy environment for business, and its problems.
the entry of strong foreign corporate contenders tends to
stimulate the host-country business sector, whether
through competition, vertical linkages or demonstration
effects. FDI can be said to act as a catalyst for underlying
strengths and weaknesses in the host countries’ corporate
environments, possibly exacerbating the problems in “non-
governance zones”, while eliciting the advantages in coun-
tries with a more benign business climate and better gover-
nance. This reinforces the point made above about the
need for host (and home) countries to work to improve reg-
ulatory and legal frameworks and other elements that help
enable the business sector.
© OECD 2002
Foreign Direct Investment for Development: Overview
V. Policy recommendations
Policies matter for reaping the full benefits of FDI. Foreign inves-
tors are influenced by three broad groups of factors: the expected profit-
ability of individual projects; the ease with which subsidiaries’
operations in a given country can be integrated in the investor’s global
strategies; and the overall quality of the host country’s enabling envi-
ronment. Some important parameters that may limit expected profit-
ability (e.g. local market size and geographical location) are largely
outside the influence of policy makers. Moreover, in many cases the
profitability of individual investment projects in developing countries
may be at least as high as elsewhere. Conversely, developed economies
retain clear advantages in the second and third factors mentioned
above, which should induce less advanced economies to undertake pol-
icy action to catch up. Important factors such as the host country’s
infrastructure, its integration into the world trade systems and the
availability of relevant national competences are all priority areas.
Sound FDI policies Sound host-country policies toward attracting FDI and
and policies toward benefiting from foreign corporate presence are largely equiva-
domestic enterprise lent to policies for mobilising domestic resources for produc-
development are tive investment. As stated in the Monterrey Declaration,
largely equivalent. domestic resources in most cases provide the foundation for
self-sustaining development. An enabling domestic business
environment is vital not only to mobilise domestic resources
but to attract and effectively use international investment.
They fall into As the experience of OECD members and other coun-
three categories, tries has shown, the measures available to host-country
namely… authorities fall into three categories: improvements of the
general macroeconomic and institutional frameworks; cre-
ation of a regulatory environment that is conducive to
inward FDI; and upgrading of infrastructure, technology and
human competences to the level where the full potential
benefits of foreign corporate presence can be realised.
… macroeconomic The first of these points establishes the fact that every
stability and quality aspect of host countries’ economic and governance prac-
of financial tices affects the investment climate. The overall goal for
24 intermediation, policy makers must, therefore, be to strive for the greatest
© OECD 2002
Summary and Conclusions
© OECD 2002
Foreign Direct Investment for Development: Overview
© OECD 2002
Summary and Conclusions
© OECD 2002
Foreign Direct Investment for Development: Overview
© OECD 2002
Summary and Conclusions
© OECD 2002
Foreign Direct Investment for Development: Overview
MNEs also have The private sector (notably foreign investors) plays a
responsibilities… vital role in generating economic growth, and contributing
to achieving sustainable development goals. Therefore, the
way private enterprises behave and are governed is impor-
tant in maximising the benefits of FDI for economic devel-
opment. OECD countries have launched several initiatives
to promote responsible corporate behaviour. Among these
are the OECD Guidelines for Multinational Enterprises.
30
© OECD 2002
Summary and Conclusions
© OECD 2002
Foreign Direct Investment for Development: Overview
… not least in areas Against the background of the Doha and Monterrey
such as investment Declarations, which identify capacity building as a priority
capacity building. area for international co-operation, international organisa-
tions and relevant national agencies should carefully assess
the need for activities in the field of international invest-
ment – particularly FDI. Increased capacity-building mea-
sures would focus on assisting developing countries to
develop stronger competences in the following fields: gen-
eral supply-side challenges; formulation and implementa-
tion of broad-based policies toward FDI; and the specific
architecture for negotiating and implementing international
treaties and agreements related to foreign investment.
The OECD is well The OECD has a key responsibility to act as a forum for
placed to contribute sharing Members’ experience with capacity building and
to these efforts… with investment instruments of co-operation. The OECD’s
distinctive methodology relies on a peer-review process
based on long-tested benchmarking for FDI policies, rec-
ommendations from governments with diverse perspec-
tives and cultures, and the monitoring of process.
32
© OECD 2002
Multinational Capital Budgeting
14. 2
Chapter Objectives
14. 3
Subsidiary versus Parent
Perspective
• Should the capital budgeting for a multi-
national project be conducted from the
viewpoint of the subsidiary that will administer
the project, or the parent that will provide most
of the financing?
• The results may vary with the perspective
taken because the net after-tax cash inflows to
the parent can differ substantially from those
to the subsidiary.
14. 4
Subsidiary versus Parent
Perspective
• Net cash flow differences can be due to:
• Tax differentials
What is the tax rate on remitted funds?
• Regulations that restrict remittances
• Excessive remittances
The parent may charge its subsidiary high administrative fees.
• Exchange rate movements
14. 5
Remitting Subsidiary Earnings to
the Parent
14. 6
Subsidiary versus Parent
Perspective
• A parent’s perspective is appropriate when
evaluating a project, since any project that can
create a positive net present value for the
parent should enhance the firm’s value.
• However, one exception to this rule occurs
when the foreign subsidiary is not wholly
owned by the parent.
14. 7
Input for Multinational
Capital Budgeting
The following forecasts are usually required:
1. Initial investment
2. Consumer demand over time
3. Product price over time
4. Variable cost over time
5. Fixed cost over time
6. Project lifetime
7. Salvage (liquidation) value
14. 8
Input for Multinational
Capital Budgeting
14. 9
Multinational
Capital Budgeting
• Capital budgeting is necessary for all long-
term projects that deserve consideration.
• One common method of performing the
analysis involves estimating the cash flows
and salvage value to be received by the
parent, and then computing the net present
value (NPV) of the project.
14. 10
Multinational
Capital Budgeting
• NPV = – initial outlay
n
+ cash flow in period t
t =1 (1 + k )t
salvage value
+
(1 + k )n
k = the required rate of return on the project
n = project lifetime in terms of periods
• If NPV > 0, the project can be accepted.
14. 11
Multinational
Capital Budgeting
Example:
• Spartan, Inc. is considering the development
of a subsidiary in Singapore that will
manufacture and sell tennis rackets locally.
14. 12
Capital Budgeting Analysis:
Spartan, Inc.
14. 13
Capital Budgeting Analysis:
Spartan, Inc.
14. 14
Capital Budgeting Analysis
Period t
1. Demand (1)
2. Price per unit (2)
3. Total revenue (1)(2)=(3)
4. Variable cost per unit (4)
5. Total variable cost (1)(4)=(5)
6. Annual lease expense (6)
7. Other fixed annual expenses (7)
8. Noncash expense (depreciation) (8)
9. Total expenses (5)+(6)+(7)+(8)=(9)
10. Before-tax earnings of subsidiary (3)–(9)=(10)
11. Host government tax tax rate(10)=(11)
12. After-tax earnings of subsidiary (10)–(11)=(12)
14. 15
Capital Budgeting Analysis
Period t
13. Net cash flow to subsidiary (12)+(8)=(13)
14. Remittance to parent (14)
15. Tax on remitted funds tax rate(14)=(15)
16. Remittance after withheld tax (14)–(15)=(16)
17. Salvage value (17)
18. Exchange rate (18)
19. Cash flow to parent (16)(18)+(17)(18)=(19)
20. PV of net cash flow to parent (1+k) - t(19)=(20)
21.Initial investment by parent (21)
22. Cumulative NPV PVs–(21)=(22)
14. 16
Factors to Consider in
Multinational Capital Budgeting
Exchange rate fluctuations
Since it is difficult to accurately forecast
exchange rates, different scenarios can be
considered together with their probability of
occurrence.
14. 17
Analysis Using Different Exchange
Rate Scenarios: Spartan, Inc.
14. 18
Sensitivity of the
Project’s NPV to
Different Exchange
Rate Scenarios:
Spartan, Inc.
14. 19
Factors to Consider in
Multinational Capital Budgeting
Inflation
Although price/cost forecasting implicitly
considers inflation, inflation can be quite
volatile from year to year for some countries.
14. 20
Factors to Consider in
Multinational Capital Budgeting
Financing arrangement
Financing costs are usually captured by the
discount rate.
However, when foreign projects are partially
financed by foreign subsidiaries, a more
accurate approach is to separate the
subsidiary investment and explicitly consider
foreign loan payments as cash outflows.
14. 21
Factors to Consider in
Multinational Capital Budgeting
Blocked funds
Some countries require that the earnings
generated by the subsidiary be reinvested
locally for at least a certain period of time
before they can be remitted to the parent. But,
why?
14. 22
Capital Budgeting with Blocked
Funds: Spartan, Inc.
• Assume that all funds are blocked until the
subsidiary is sold.
14. 23
Factors to Consider in
Multinational Capital Budgeting
Uncertain salvage value
Since the salvage value typically has a
significant impact on the project’s NPV, the
MNC may want to compute the break-even
salvage value.
Impact of project on prevailing cash flows
The new investment may compete with the
existing business for the same customers.
14. 24
Factors to Consider in
Multinational Capital Budgeting
Host government incentives
These should also be incorporated into the
analysis.
Real options
Some projects contain real options for additional
business opportunities.
The value of such a real option depends on the
probability of exercising the option and the
resulting NPV.
14. 25
Adjusting Project Assessment
for Risk
• When an MNC is unsure of the estimated cash
flows of a proposed project, it needs to
incorporate an adjustment for this risk.
• One method is to use a risk-adjusted discount
rate. The greater the uncertainty, the larger the
discount rate that should be applied to the
cash flows.
14. 26
Adjusting Project Assessment
for Risk
• An MNC may also perform sensitivity analysis
or simulation using computer software
packages to adjust its evaluation.
• Sensitivity analysis involves considering
alternative estimates for the input variables,
while simulation involves repeating the
analysis many times using input values
randomly drawn from their respective
probability distributions.
14. 27