International taxation and corporate strategy: evidence from British overseas business, circa 1900–1965

Abstract

In this article we establish the impact and importance of international taxation on British overseas business circa 1900 to 1965. As the levels of national taxation rose across the twentieth century, different states began to compete for taxable income. This created international double taxation whereby taxation was due twice on the same income or profit. We examine the difficulties that this caused and the responses of firms to this challenge, through the adoption of tax-minimisation strategies, alterations to corporate structure, and the relocation of corporate domicile. We discuss how international taxation was one of the secular changes in the international business environment that contributed to the rise of large-scale multinational enterprises. We conclude by making a call for greater consideration of international taxation in international business history.

Keywords::

• international taxation
• international business environment
• international tax system
• corporate domicile
• international business history
• British free-standing company (FSC)

Acknowledgements

Versions of this article were presented at seminars at Aston, the LSE, and York, and also at the Association of Business Historians conference in York in 2010. The authors would like to thank the following people for their useful comments – Neveen Abdelrehim, Mike Anson, Mark Billings, Chris Colvin, Bill Cooke, Stephanie Decker, Roy Edwards, Philip Garnett, Terry Gourvish, Les Hannah, David Higgins, Josephine Maltby, Lynne Oats, Mitch Larsson, Ranald Michie, Rory Miller, Andrew Popp, Mick Rowlinson, John Quail, Steve Toms and John Wilson. All errors remain ours.

Notes

1. The Financial Times, n.d.

2. Holder, “Tax Policymakers.”

3. BBC News, “Starbucks.”

4. Bond and Samuelson, “Strategic Behaviour”; Shah and Slemrod, “Do Taxes Matter?”; Tanzi, Taxation; Giddens, The Nation-state; Held, McGrew, Goldblatt, and PerratonGlobal Transformations; Paris, “The Globalization”; Profeta and Scabrosetti, The Political Economy; , “The Control” and “Slicing a Shadow”; Avi-Yonah, International Tax.

5. Toms and Higgins, “Public Subsidy,” 60.

6. Buckley, “Business History”; Wilkins, “Multinational Enterprise”; Walton, “New Directions.”

7. Avery Jones et al., “The Origins”; Avery Jones, “The History”, “The Definition”, and “The United Kingdom's Influence”; Taylor, “The Negotiation”; Hemetsberger-Koller and Kolm, “Globalization.”

8. Isaac, Mehrota, and Prasad, The New Fiscal; Rixen, The Political Economy; Nehring and Schui, Global Debates.

9. See, for example, Napier, “Secret Accounting”; Bowden and Maltby, “‘More a National Asset”; Toms and Higgins, “Public Subsidy”; Rutterford, “From Dividend Yield”; Oats, “Distinguishing”; Billings and Capie, “Capital”; Cheffins and Bank, “Corporate Ownership.”

10. Daunton, Just Taxes.

11. Stockwell, “Trade.”

12. An example is Merchants to Multinationals by Geoffrey Jones. This book is a good example of recent international business history by a leading business historian. International taxation and its impact on firm strategy does feature, but only somewhat. On p. 127 eight lines discuss an example, while on p. 171 13 lines discuss two examples. In total, in a book that is slightly over 400 pages long international taxation is discussed for roughly half a page in total. Jones, Merchants to Multinationals, 127, 171. An exemplary article that looks at German international business and the impact of taxation is Kobrak and Wüstenhagen, “International Investment and Nazi Politics”.

13. This point is elegantly made by Michel Foucault with reference to the classification of nature by natural historians, criticised for the “application of categories that are strictly anachronistic…”. He goes on: “Historians want to write histories of biology in the eighteenth century; but they do not realise that biology did not exist then, and that the pattern of knowledge that has been familiar to us for a hundred and fifty years is not valid for a previous period.” Foucault, The Order of Things, 139. Foucault draws a contrast between living things in nature, and ‘biology’ as a system of knowledge.

14. Lippmann and Aldrich, “History,” 140.

15. Booth and Rowlinson point to the dangers of presentism in organisational history research, warning of the risks of an ‘ahistorical’ approach which assumes that the organisational context of the present remained the same through history. Taylor, Bell, and Cooke point further to their perceived need for business history to become aware of Ricoeur's notion of memory and forgetting, particularly in the context of history's apparent ignorance of the development of social science theory, in this case the theory of reflexivity, which Taylor, Bell and Cooke suggest should be integrated into the writing of business history. Toms and Wilson argued in defence of traditional historical method, suggesting that a more ‘eclectic’ approach to theory was necessary. According to Toms and Wilson debates that appeared to be esoteric, such as those around the size of coal wagons, were relevant as they provided historical evidence to cognate disciplines, while remaining historically grounded. Our view is that business historians should be prepared to explain the choices they have made in their research design and process, exposing as it does the weaknesses of their methods. See: Booth and Rowlinson, “Management”; Taylor, Bell, and Cooke, “Business History”; Ricoeur, Memory; Toms and Wilson, “In Defence.” The recent edited volume by Marcelo Bucheli and Dan Wadhwani contains chapters by a variety of authors which advances further the growing field examining the role that social science theories play in business and management history. See: Bucheli and Wadhwani, Organizations in Time.

16. Popp and Holt, “The Presence.”

17. Lippmann and Aldrich, “History.”

18. Desai, Foley, and Hines Jr, “Foreign Direct Investment”; Eden, Taxing Multinationals, and “Taxes”; James, “Taxation”; Glaister and Hughes, “Corporate Strategy Formulation.”

19. Channing and Jalland, Multinational Strategic Planning, 150.

20. Razin and Slemrod, “Introduction,” 2.

21. Eden, “Taxes,” 599.

22. Neumayer, “Do Double.”

23. Federation of British Industries, Royal Commission; Carroll, Prevention.

24. Kemsley, “The Effect”; Altshuler and Grubert, “Where Will They Go”; Bénassy-Quéré, Fontagné, and Lahrèche-Révil, “How Does FDI React.”

25. Tanzi, Taxation, 6.

26. De Mooij and Ederveen, “Taxation.”

27. Voget, “Relocation.”

28. Neumayer, “Do Double.”

29. Grubert and Mutti, “Taxes, Tariffs”; Bartelsman and Beetsma, “Why Pay More?”; Jacob, “Taxes”; Elitzur and Mintz, “Transfer Pricing”; Clausing, “The Impact”; Eden, Taxing Multinationals.

30. Channing and Jalland, Multinational Strategic Planning; Smith, Tax Avoidance; Fuest and Hemmelgarn, “Corporate Tax Policy”; Buettner, Overesch, Schreiber, and Wamser, “The Impact.”

31. As the Google N-Grams graph available at the address below indicates it is in the 1970s that the term came into common use. http://books.google.com/ngrams/graph?content=transfer-pricing&year_start=1950&year_end=2010&corpus=15&smoothing=0&share=. The first usage in The Financial Times was in 1968, The Times in 1970, and The Economist in 1971. See “The Divisional Profits Conundrum.” Financial Times [London, England] 6 March 1968, 15; “The Trans National Companies,” The Times [London, England], 5 January 1970, 21; “Buying a slice of America.” The Economist [London, England] 9 October 1971, 90.

32. This can be seen in the Google N-Grams graph available at the address below. http://books.google.com/ngrams/graph?content=thin+capitalization%2cthin+capitalisation&year_start=1800&year_end=2008&corpus=15&smoothing=0&share=. This is consistent with its appearance in The Times, where the first use of the term is in 1989. In The Financial Times the term is only used for the first time in 1995. See “All the Budget Form.” The Times [London, England] 11 March 1989, 23; Jon Ashworth. “Fears of US Tax Crackdown on UK Firms Subside.” The Times [London, England] 5 November 1992, 31; Schwarz, Jonathan. “New Laws Limit Profit Shifting.” Financial Times [London, England] 24 February 1995, 35.

33. Wilkins makes this claim twice. Wilkins, “The Free-standing,” 31, 39.

34. Miller, “British Free-standing”; Stockwell, “Trade.”

35. On the subject of British FDI, see Sidney Pollard and Christopher Platt: Pollard, “Capital Exports”; Platt and Martin, Britain's Investment. There has never been a robust estimate of the number of FSCs, but Wilkins drew heavily on Tom Houston and John Dunning's establishment of a concept of the ‘bilateral organisation’, so called because they were based in the UK but invested in only one company. Houston and Dunning used the Stock Exchange Year Book to establish that 2640 bilaterals existed. Harvey and Press added to this number for British overseas mining firms, indicating that in 1894 there were 415, while by 1913 there were 957. Kevin Tennent found 118 such companies registered in Scotland alone between 1862 and 1885. See: Pollard, “Capital Exports”; Platt and Martin, Britain's Investment; Wilkins, “The Free-standing Company”; Houston and Dunning, UK Industry; Harvey and Press, “The City”; Tennent, “Owned, Monitored.”

36. Wilkins, “The Free-standing Company”; Casson, “An Economic Theory.”

37. Jones, Merchants to Multinationals.

38. Wilkins, “The Free-standing Company”; Wilkins, “The Free-standing.”

39. Jones, Ghobadian, O’ Regan, and Antcliff (2013) used newspaper sources extensively for factual sources. Tennent's (2013) study of distribution in the British music industry was constructed almost entirely from trade paper and newspaper sources.

40. Kynaston, The Financial Times.

41. Wilkins, “The Free-standing Company.”

42. For example, Harvey and Press, “The City.” More recent studies have also used these mixed approaches, but with a less than clear exposition of methodology, including David Boughey's work on railways which used the Stock Exchange Year Book and the Directory of Directors, while Shaw, Curth and Alexander, and Quinn and Sparks, both made extensive use of The Grocer in their work on grocery wholesaling and symbol groups. See: Boughey, “British Overseas”; Shaw, Curth, and Alexander, “Selling Self-service”; Quinn and Sparks, “The Evolution.” Mixed periodical and industry directory based methodology is the conventionally accepted norm for business history study which relates to a large number of individual firms yet still requires some realisation of firm based detail.

43. Fischer, “Historical Sociology”; Rowlinson and Hassard, “Historical Neo-institutionalism.”

44. This periodisation is well established in international business history and in political economy. See Kenwood and Lougheed, Growth.

45. Harris, “An Historic View.”

46. Worldwide Tax Treaty Index1997/98 Edition.

47. “To Aid World Commerce,” The Times [London, England], 24 March 1921, 9; “International Law,” The Times [London, England], 3 September 1921, 7; “Empire Chamber of Commerce,” The Times [London, England], 30 September 1924, xix; “Taxation Problems,” The Times [London, England], 28 October 1924, 11.

48. “Double Taxation,” The Accountant, 8 April 1922, 462; “Double Taxation and Fiscal Evasion,” The Accountant, 10 November 1923, 661. The 1932–33 model is of interest because it is the origin of the arm's length standard for transfer pricing, which remains the basis for the taxation of multi-unit corporations. Eden, Taxing Multinationals; Avi-Yonah, International Tax.

49. Avery Jones, “The History,” “The United Kingdom's Influence,” and “The Definition”; Rixen, The Political Economy.

50. This is notwithstanding the relatively large number of agreements entered into to deal with shipping enterprises of which there were over seventy by 1939. Carroll, Prevention, 42. Koch, The Double; OECD, Draft Double Tax; Carroll, “The Development.”

51. “Colonial Income Tax,” The Accountant, 20 January 1923, 93–109; “New York Stock Exchange,” The Times [London, England], 16 July, 1938, 20; “City Notes: Double Taxation,” The Times [London, England], 20 December 1938, 21.

52. “City Notes: Double Taxation,” The Times, 20 December 1938, 21.

53. “Double Taxation Within the Empire,” Financial Times [London, England], 1 July 1916, 4.

54. “City Notes: Double Taxation,” The Times [London, England], 20 December 1938, 21.

55. “Cooper, McDougall and Co.,” The Times [London, England], 29 March 1940, 3.

56. “Double Tax Burden,” Financial Times [London, England], 2 May 1944, 2; “The Problem of Double Taxation—III,” Financial Times [London, England], 31 March 1945, 2.

57. “Double Tax Talks,” Financial Times [London, England], 23 August 1944, 2.

58. “Matador Land and Cattle Company – Burden of Double Taxation,” The Times [London, England], 12 April 1945, 9; “Matador Land Meeting,” The Times [London, England], Thursday 12 July 1951, 9.

59. Royal Commission on The Taxation of Profits and Income, First report. (P.P., 1952–3, XVII). Cmd. 8761. 9; see also Stockwell, “Trade.”

60. “Double Taxation Relief,” Accountancy, February 1963, 149.

61. OECD, Draft Double Tax, 23.

62. Rixen, The Political Economy.

63. Davis and Huttenback, Mammon; Davis, “The Late”; Pollard, “Capital Exports”; Platt, “British Portfolio”; Platt, Britain's Investment; Schmitz, “The Nature.”

64. Sabine, A History.

65. “Company Meetings: Farmer and Co.”; The Times [London, England], 17 November 1916, 15; “Dalgety and Company (Limited). A Successful Year, The Double Income Tax. Question,” The Times [London, England], 24 November 1916, 15.

66. See Peden, The Treasury. Especially Ch. 2, “Liberal Finance and Social Reform, 1906–1914,” 30–72; data from p. 94. In addition, see Arnold for a guide to changes to the tax system in the inter-war period. Arnold, “‘Publishing”; Arnold, “Profitability.”

67. Sabine, A History; Peden, The Treasury.

68. “Colonial Taxes,” The Accountant, 5 November 1921, 621; “Double Taxation,” Taxation, 26 October 1957, 68–71. For worldwide increases to taxation see: Walton and Rockoff, History; Dyster and Meredith, Australia; Hughes and Cain, American Economic History; Brownlee, “The Public Sector.”

69. “Company Tax Rates Overseas,” Accountancy, May 1963, 423–427; “Taxation: The Finance Act, 1963,” Accountancy, December 1963, 1099.

70. “Double Income Tax,” The Economist, 4 March 1916, 451; “Investment Under the Flag: Perils of Double Income Tax,” The Times [London, England], 29 February 1916, 3.

71. “Double Income Tax,” The Economist, 4 March 1916, 451.

72. “Double Income Tax,” The Economist, 4^th March 1916, 451.

73. “Letter to the Editor by ‘Merchant’,” The Economist, 28 September 1918, 398.

74. “Letter to the Editor by ‘Merchant’,” The Economist, 28 September 1918, 398.

75. “S. Hoffnung and Co. Ltd: Proposed Capitalisation of Reserves,” The Times [London, England], 27 July 1920, 21.

76. “Company Meeting. Dalgety and Co. Ltd,” The Times [London, England], 20 November 1920, 18; “Dalgety and Co. Ltd,” The Times [London, England], 18 November 1921, 21.

77. “Joseph Nathan and Co Ltd: Remarkable Development of Glaxo,” The Times [London, England], 20 April 1921, 20.

78. Davenport-Hines and Slinn, Glaxo.

79. “Bovril Ltd: How Income Tax Affects British Exports,” The Times [London, England], 20 February 1931, 21.

80. “Forestal Land, Timber and Railways: 24^th Annual General Meeting,” The Times [London, England], 27 May 1930, 24.

81. Cowan, “Capital.”

82. Jones, Merchants to Multinationals.

83. “Anglo-Continental Supply Company Ltd: Scheme of Arrangement,” The Times [London, England], 25 April 1922, 20.

84. “Erinoid Ltd,” The Times [London, England], 4 November 1927, 23; “Erinoid Ltd,” The Times [London, England], 22 October 1930, 23.

85. “Godfrey Phillips, Ltd,” The Times [London, England], 17 April 1930, 23.

86. “Olympic Portland Cement Company,” The Times [London, England], 29 April 1933, 23.

87. “Olympic Portland Cement,” The Times [London, England], 23 May 1939, 23; 26 May 1942, 7; 17 July 1943, 8.

88. “Imperial Continental Gas Association,” Financial Times [London, England], 21 May 1931, 4.

89. Federation of British Industries, Royal Commission on the Taxation of Profits and Income 1952, 1952, 1.

90. “Double Taxation,” The Times [London, England], 29 April 1950, 7.

91. For example, see “Matador Land and Cattle Company – Burden of Double Taxation,” The Times [London, England], 12 April 1945, 9; “Goode Durrant and Murray – Effect of Double Taxation,” The Times [London, England], 10 January 1946, 8; “Central Sumatra Rubber Estates – Burden of Double Taxation,” The Times [London, England], 30 December 1949, 8; “Harrods (Buenos Aires) Ltd – Crushing Burden of Double Taxation,” The Times [London, England], 24 February 1950, 11; “The Ever Ready Trust Co. Ltd – Mr Perry's Views on Double Taxation,” The Times [London, England], 9 June 1952, 9; “Agar, Cross and Company – Double Taxation Crippling Operations,” The Times [London, England], 1 January 1952, 14; “British-American Tobacco Company Limited – Problem of Double Taxation Still Unsolved,” The Times [London, England], 10 May 1954, 11; “Consolidated African Selection Trust – Gold Coast Double Taxation Handicap,” The Times [London, England], 16 December 1955, 14.

92. Federation of British Industries, Royal Commission on the Taxation of Profits and Income 1952, 1952, 48.

93. “An Exodus to Rhodesia,” The Times [London, England], 25 October 1950, 8; Exchange Control Act 1947: 10 & 11 Geo. 6 Ch. 14. London: HMSO, 1947.

94. “City Notes,” The Times [London, England], 4 February 1952, 9; The Finance Act, 1951: 14 & 15 Geo. 6 Ch.43. London: Butterworth, 1951.

95. National Archives (NA) T312/1 Memo Section 468 of the Income Tax Act, 1952 and Union Corporation Ltd [c.,1960]

96. NA IR40/12666 Rhodesian Selection Trust, Proposed Transfer of Residence to Norther Rhodesia (1952), Report, December 1952. Calculation made using the GDP deflator: Officer and Williamson, “Five Ways to Compute the Relative Value of a UK Pound Amount, 1270 to Present.”

97. “Leach's Estates to Change Domicile,” The Times [London, England], 6 March 1950, 9.

98. See Report of the Departmental Committee on Taxation and Overseas Minerals. London: HMSO, 1949. Cmd. 7728, 22.

99. “An Exodus to Rhodesia,” The Times [London, England], 25 October 1950, 8; NA IR40/12666 Rhodesian Selection Trust, Proposed Transfer of Residence to Norther Rhodesia (1952).

100. “Roan Antelope Copper Mines Ltd,” The Times [London, England], 4 February 1952, 8.

101. “City Notes,” The Times [London, England], 4 February 1952, 9.

102. “City Notes,” The Times [London, England], 24 May 1952, 9.

103. “R.S.T. Change of Domicile,” The Times [London, England], 1 May 1953, 13.

104. “Roan Antelope Copper Mines Limited,” The Times [London, England], 22 November 1952, 12.

105. “New Broken Hill Consolidated Ltd,” The Times [London, England], 26 June 1952, 12.

106. “City Notes,” The Times [London, England], 18 July 1952, 10.

107. “Edgar Allen and Co.,” The Times [London, England], 13 August 1954, 11.

108. “The South West Africa Company, Ltd,” The Times [London, England], 9 February 1956, 15.

109. This problem had long been recognised as posing a problem for mining firms. See Report of the Departmental Committee on Taxation and Overseas Minerals. London: HMSO, 1949. Cmd. 7728, 17.

110. “Union Corporation Domicile,” The Times [London, England], 19 September 1958, 18; “Union Corporation's Residence,” The Times [London, England], 11 July 1962, 14.

111. Frankel, Investment and the Return to Equity Capital in the South African Gold Mining Industry.

112. “Union Corporation Pays 10% More.” Financial Times [London, England], 21 March 1957, 8.

113. If the tax estimated to be lost to the British Exchequer (i.e. gained by the company) is added to the post-tax profits of the company, the profits will increase by the percentages listed below, calculated as follows.

	£150,000 / £1,900,000 x100 = 7.9%
	£300,000 / £1,900,000 x100 = 15.8%
	£150,000 / £949,229 x100 = 15.8%
	£300,000 / £949,229 x100 = 31.6%

This is a crude but nonetheless indicative measure of the impact of international taxation on corporate profit.

114. This is calculated as follows:

	£150,000 / £1,162,500+£4,182,692+£5,061,365 = 1.44%
	£300,000 / £1,162,500+£4,182,692+£5,061,365 = 2.88%

Formula used:

Increase to profit / share capital + revenue reserve (minus profit and loss account) + capital reserve =  potential increase to return on equity

Data: Stock Exchange Year Book1958, 1201–1202.

115. At 2009 prices £300,000 would be £5.09 million using the GDP deflator: Officer and Williamson, “Five Ways” and “Union Corporation, Limited.” Financial Times [London, England], 16 July 1957, 10: National Archives (NA) FO 371/155548 Memo by T.W. Aston, 7 December 1961; NA T 312/1 Letter from SA Minister of Finance to Ch. Of the Exch. (Feb 1961); T 312/1 Letter from Chairman of the Union Corporation to the Treasury, 7 Dec 1961.

116. NA FO 371/15554 Memo by T.W. Aston, 7 December 1961.

117. NA FO 371/15554 Letter to Selwyn Lloyd (Chancellor) from Secretary of State 23 Dec 1961.

118. NA FO 371/15554 Confidential Memo: ‘Union Corporation: Application to Transfer Resident to South Africa’ 21 December 1961.

119. NA FO 371/15554 Letter to Selwyn Lloyd (Chancellor) from Secretary of State 23 Dec 1961; NA FO 371/15554 Cables to FO office Cape Town, 18 January 1962 – #15 Union Corporation; NA FO 371/15554 Cable to Cape Town (n.d.) Re telegram of 23 January 1962; “Union Corporation's Residence,” The Times [London, England], 11 July 1962, 14.

120. For example see: “The Consolidated Mines Selection Company Limited – Influence of Double Taxation Relief,” The Times [London, England], 3 March 1959, 15; “United British Securities Trust, Limited,” The Times 20 August 1965, 14.

121. Stockwell, “Trade,” 146.

122. See Stanford (1958) and “The Opening of a Branch Outside the United Kingdom,” Taxation, 3 November 1962, 100–101.

123. “Union Corporation: No O. T. C. Benefit.” Financial Times [London, England], 29 May 1957, 11. This was a generally reported phenomenon, see “Overseas Trade Corporation,” Taxation, 14 July 1962, 245.

124. “Overseas Trading Corporations,” Taxation, 7 March 1959, 472.

125. “British Overseas Mining Association Urgent Need For Tax Relief, Hopes For Early Introduction Of Overseas Trade Corporations,” The Times [London, England], 20 December 1956, 15; “Tax Concessions for Overseas Trading,” The Times [London, England], 2 June 1965, 12; “Budget to Close the Gap,” The Times [London, England], 7 April 1965, 15.

126. Stockwell, “Trade.”

127. Ibid., 154.

128. “The London and Lancashire Insurance Co. Ltd: 60^th Ordinary General Meeting,” The Times [London, England], 4 May 1922, 24.

129. “Another Insurance Fusion,” Financial Times [London, England], 17 August 1917, 3; “London and Lancashire Insurance,” Financial Times [London, England], 13 April 1923, 5; Stock Exchange Yearbook, 1923 (Thos, Skinner and Co, London, 1923), 734–735; Stock Exchange Official Intelligence (Thos. Skinner, London, 1914), 1202.

130. Jones, “Commercial Banks.”

131. Jones, British Multinational.

132. “London Bank of Australia, Limited,” The Economist [London, England], 18 May 1918, 895; “National Bank Of New Zealand, Limited,” The Economist [London, England], 27 July 1918, 118.

133. “London, Singapore and Java Bank Ltd: Expansion of Business,” The Times [London, England], 15 May 1920, 20.

134. “Bank of Australasia,” Financial Times [London, England], 1 April 1932, 7; “Union Bank of Australia,” Financial Times [London, England], 31 January 1939, 4; “Union Bank Of Australia, Limited,” The Economist [London, England], 4 February 1939, 271.

135. “Bank of Australasia,” Financial Times [London, England], 19 March 1946, 2; “Union Bank of Australia,” Financial Times [London, England], 11 January 1946, 3.

136. “Union Bank of Australia,” Financial Times [London, England], 17 January 1947, 2; “National Bank of New Zealand,” Financial Times [London, England], 17 July 1947, 3; “Union Bank of Australia,” Financial Times [London, England], 9 January 1948, 2.

137. “Bank of London & South America Limited,” The Economist [London, England], 27 November 1948, 900; “Bank of London and South America,” Financial Times [London, England], 26 November 1948, 2; “Bank of London & South America Limited,” The Economist [London, England], 25 November 1950, 916; “Bank of London & South America Limited,” The Economist [London, England], 10 March 1951, 570; “Bank of London & South America,” Financial Times [London, England], 9 March 1951, 2.

138. “Chartered Bank of India, Australia, and China,” The Economist [London, England], 18 March 1950, 626

139. Wilkins and Schröter, The Free-standing; Jones, “British Overseas Banks.”

140. Mollan, “International Banking.”

141. “The Union Bank of Scotland, Limited,” The Economist [London, England], 19 May 1945, 671; “Barclays Bank (Dominion, Colonial and Overseas),” The Economist [London, England], 18 December 1965, 1380.

142. Wilkins, “The Free-standing”; Miller, “British Free-standing”; Stockwell, “Trade.”

143. This is consistent with the decline of the City of London as a location for the headquarters of FSCs, connected to the decline of the commercial services provided there. See Mollan and Michie, “The City.”

144. Chapman, “British-based.”

145. Frankel, Investment.

146. The newly merged RTZ used debt-financing for some subsidiaries and sub-subsidiaries in way that is consistent with the notion of thin capitalisation. See “The Rio Tinto-Zinc Corporation Limited,” Financial Times [London, England], 24 May 1963, 4.

147. Jones, Merchants to Multinationals; Chandler, Scale and Scope; Buckley and Casson, The Future.

148. Jones, Multinationals; Jones, Merchants to Multinationals; Davis, “The Late.”

149. Teece, “Explicating.”

150. Chia and Holt, Strategy Without Design.

151. Chandler, Scale and Scope; Johanson and Vahlne, “The Internationalization.”

152. Teece, “Explicating”; Teece, Pisano, and Shuen, “Dynamic Capabilities”; Mollan and Michie, “The City”; Barney, Wright, and Ketchen, “The Resource-based.”

153. White, “Internal Organization.”

154. It was a concern during the decolonization period that foreign enterprises might relocate as a result of taxation levels. See Levin, The Export.

155. For example, see Tolliday, Business; Nicholas, “Locational Choice.”

156. For an example of the kind of research that is possible in this area see Lynch, “Harmonization.”

Additional information

Notes on contributors

Simon Mollan

Simon Mollan is a Senior Lecturer at The York Management School.

Kevin D. Tennent

Kevin D. Tennent is a Lecturer at The York Management School.