固定资产折旧、税收筹划与异常投资

Fixed Assets Depreciation, Tax Planning and Abnormal Investment

观察中国非金融类上市公司的季度数据可知,企业固定资产投资更多发生在第4季度,即存在“异常投资”行为。针对这一特征事实,本文试图从税收筹划视角进行解释。基于两期投资模型的理论表明,给定固定资产折旧具有税收规避功能,企业推迟投资并在获取更多财务信息后再做投资决策,相当于持有一项“等待期权”。企业经营不确定性越大,“等待期权”价值越高,年末投资以降低所得税负担的动机越强。进一步,基于加速折旧政策出台的双重差分估计结果显示,加速折旧政策显著弱化了试点行业的“异常投资”行为,而且该效应在盈利能力强、所得税税率高、财务信息不确定性高和劳动密集型的企业相对较小。特别地,试点行业在加速折旧政策实施之后的资本配置效率得到显著改善,尤其发生在“异常投资”程度高的企业,这反映出“异常投资”行为在帮助企业实现税收规避的同时,会损害其长期绩效。本文强调,理解企业的税收筹划动机对于推动财税政策改革以助力投资提质增效具有重要启示意义。

By observing the quarterly data of Chinese non-financial listed companies, an interesting phenomenon can be found that firms tilt capital purchases toward the fourth quarter, which is called the abnormal investment behavior. This paper argues that the phenomenon is driven by the incentives of firms for tax planning. Specifically, firms face a high degree of financial uncertainty in the first three quarters, so they cannot accurately predict year-end earnings and taxable incomes, leading to more cautiousness about fixed assets investment. In the fourth quarter, firms are able to determine the current year's earnings more accurately and have a stronger incentive to minimize their tax burden by increasing their capital expenditures. Taken together, because the accelerated depreciation policy allows firms to achieve the same tax credit with less investment in the fourth quarter and the depreciation of investments in the first three quarters also increases, it should decrease the abnormal investment behavior if firms' higher capital expenditures at the fiscal year-end are to reduce their tax bill.To test this prediction, this paper builds a two-period model to illustrate how the accelerated depreciation policy shapes the abnormal investment behavior of firms. Given investment depreciation plays a role in tax avoidance, enterprises postpone fixed assets investment and make investment decisions after obtaining more financial information, which is equivalent to holding a “waiting option”. The greater the uncertainty of business operation, the higher the “waiting option” value and the stronger the incentive to invest at the end of the year to reduce the income tax burden. The difference-in-differences results show that the accelerated depreciation policy reduces the abnormal investment behavior in pilot industries, and this effect is less pronounced in firms with greater profitability, effective income tax rate, operating uncertainty and labor intensity. In addition, capital allocation efficiency in pilot industries increases after the accelerated depreciation policy, particularly for firms with more serious abnormal investments, suggesting that abnormal investment behavior damages firms' long-term performance while achieving tax evasion.The most closely related work to this paper is Xu Zwick(2020). Given the accelerated depreciation policy increases the tax credit for fixed assets investment, they point out that it strengthens firms' tax planning incentives through additional investment, while this paper argues that the increased tax deduction benefits of additional investment weaken firms' tax planning incentives. The opposite findings between the United States and China can be attributed to the imperfect financial system in China. Specifically, firms can conduct tax planning at the end of the year due to the “tax shield effect” of fixed assets investment, which is equivalent to reducing the funding cost of additional investment in the fourth quarter. It is more critical for Chinese firms with greater financial constraints. Thus, Chinese firms are more inclined to invest in fixed assets in the fourth quarter, leading to more severe abnormal investments, which determines the effect of the accelerated depreciation policy.This paper makes three main contributions to the existing literature. First, based on the quarterly capital expenditure data of Chinese listed companies, the paper finds that firms prefer to invest in fixed assets in the fourth quarter and explains that this abnormal investment behavior is driven by the incentives of firms for tax planning, which helps to comprehensively understand the logic of corporate investment behavior. Second, the paper connects two different strands of literature on abnormal investment behavior and earnings management. Essentially, the abnormal investment behavior that the paper focuses on can be regarded as an earnings management strategy. Firms allocating more capital expenditure to the fourth quarter can not only adjust their earnings but also help them obtain the “tax shield” value caused by investment depreciation, ultimately achieving their tax avoidance goals. Third, our findings have some important policy implications. In the “new development” stage, optimizing investment structure and improving capital allocation efficiency are crucial determinants of high-quality growth regime. This paper finds that the accelerated depreciation policy reduces corporate abnormal investment and improves capital allocation efficiency, resulting in better corporate performance. Therefore, expanding the implementation scope of the accelerated depreciation policy and optimizing their tax incentives can be an important means to stimulate enterprise dynamism and promote high-quality economic development.