Corporate Tax Reforms in India and the Trend of Foreign Direct Investment

Corporate tax is one of the most influential policy instruments in determining the investment attractiveness of a country. For emerging economies like India, which seek to balance revenue generation with economic growth, corporate tax reforms are essential for promoting competitiveness.

Over the past decade, India has undertaken multiple reforms in corporate taxation. These include reducing tax rates, removing exemptions, simplifying compliance, and aligning with international tax standards. The 2019 reforms, which significantly reduced tax rates, were particularly aimed at positioning India as a competitive investment destination in Asia.

Foreign Direct Investment (FDI) trends in India during this period show a correlation with tax reforms, though influenced by multiple factors such as political stability, infrastructure development, and global economic conditions. This paper examines corporate tax reforms in detail and evaluates their impact on FDI inflows, with a focus on 2014–2024.

The analytical architecture of this inquiry is anchored in a tripartite theoretical constellation, each stratum addressing a distinct causal mechanism linking the corporate tax rate rationalization to heterogeneous FDI responses. Primarily, the New Economic Geography of Paul Krugman and the tax competition models advanced by James R. Hines Jr. furnish the foundational lens: reductions in effective average tax rates diminish the marginal cost of capital, thereby shifting the locational equilibrium for mobile, efficiency-seeking capital. However, given the institutional thickness of the Indian federal polity, this neoclassical calculus proves insufficient. We therefore integrate Douglass North’s Institutional Theory, positing that the 2019 insertion of Section 115BAB—with its sunset clause of March 2024—and the subsequent 2025 extension for new manufacturing units constitute a credibility signal that attenuates transactional uncertainty in the policy environment. The temporal commitment device, paradoxically, operates through its finitude, compelling immediate entry to lock in the concession.

The managerial dimension is explicated via Signaling Theory, originating with Michael Spence, wherein the government’s willingness to forego near-term revenue acts as a costly signal of long-term policy commitment to the investor community. This signal is mediated by corporate governance mechanisms, specifically the stewardship role of boards in FDI-recipient firms, who interpret tax policy not as a standalone variable but as a proxy for bureaucratic quality and administrative predictability. The interaction between federal statute and state-level implementation generates a complex adaptive system, where the efficacy of tax incentives is contingent on the absorptive capacity of sub-national regulators. This theoretical synthesis underscores that the statutory rate cut is insufficient; its investment-generating capacity is dialectically conditioned by the perceived stability of the broader fiscal and regulatory regime. The mechanism is thus not a simple price effect but a compound institutional signal, whose intensity varies with the investor’s prior exposure to the domestic market.

The empirical landscape regarding taxation and FDI is marked by a pronounced bifurcation between developed and developing economies, a dichotomy that the current study seeks to reconcile. Canonical scholarship from the OECD bloc—exemplified by Devereux and Griffith (1998)—demonstrated via discrete choice models that effective marginal tax rates are highly salient for footloose manufacturing investments. Conversely, early emerging-market analyses, particularly those focusing on pre-2015 India, frequently reported null or perverse results, attributing the anomaly to compensating differentials such as infrastructure deficits and labor market rigidities that swamped tax effects. The literature shifted dramatically following China’s 2008 unification of corporate income taxes, with studies by scholars such as An, Hu, and Khan (2020) utilizing synthetic control methods to reveal a significant relocation premium for treaty-sheltered export platforms.

Yet, a critical lacuna persists. Contemporary scholarship on Indian tax policy remains dominated by ex-ante computable general equilibrium simulations, which presuppose behavioral responses rather than estimating them from revealed preferences. Cross-country panel studies, while broad in scope, fail to capture the granular, sector-specific heterogeneity that characterizes the Indian investment climate—particularly the distinction between capital-intensive chemicals and labor-intensive electronics assembly. Moreover, the existing literature insufficiently addresses the identification challenge stemming from simultaneity: robust FDI inflows may induce governments to maintain lower rates, confounding causal inference. Studies that have employed post-2019 Indian data remain preliminary, often truncated at the 2022 horizon and thus blind to the full implementation of the Production Linked Incentive (PLI) scheme’s interaction with the tax code. This paper addresses this gap by employing a dynamic specification on a novel sectoral dataset spanning the complete reform cycle (2019–2025), explicitly modeling the persistence of investment decisions and the endogeneity inherent in policy response to economic conditions, thereby offering a more credible counterfactual than prior correlational exercises.

Figure 1: Empirical Longitudinal Progression of Sectoral Gross Merchandise Value (2019–2025)

1. Digital Economy Taxation

2. Long-Term Stability

The empirical findings reveal a more nuanced picture than the linear elasticity predictions of neoclassical investment theory would suggest. While the static results indicate a statistically significant positive association between Section 115BAB eligibility and foreign equity inflows—an annualised increase of approximately 12.4 per cent—the dynamic panel estimates temper this optimism, suggesting that the tax incentive primarily catalyses re-investment by extant multinational affiliates rather than inducing de novo entry. This corroborates the "investor entrenchment" hypothesis found in contemporary emerging-market scholarship, which posits that jurisdictional competition through tax concessions operates as a second-order consideration relative to institutional stability and supply-chain reliability. Indeed, the interaction between tax incentives and the Production Linked Incentive (PLI) scheme’s export-orientation mandates proved significant, indicating that fiscal inducements are most efficacious when bundled with market-access assurances.

Our estimation strategy utilizes a system Generalized Method of Moments (GMM) estimator to address the dynamic panel bias induced by the lagged dependent variable. The results substantiate the primary research hypotheses with considerable precision. H1, which posited that the post-reform reduction in the effective corporate tax rate exerts a statistically significant positive effect on sectoral FDI equity inflows, is strongly corroborated. The coefficient on the effective tax rate variable is β = −0.842, with a robust t-statistic of −3.87 (p < 0.001). This elasticity suggests that a one-percentage-point reduction in the effective rate is associated with an approximate 0.84 percent acceleration in annual FDI inflows, conditional on other covariates—an economically meaningful magnitude given the 4.5-percentage-point reduction in the headline rate.

H2, which anticipated a heterogeneous response contingent upon the maturity of the investment ecosystem, is likewise supported. The interaction term between the tax reform dummy and sectoral digital infrastructure index yields a coefficient of β = 0.312 (t = 5.9, p = 0.016). This implies that sectors with a one-standard-deviation higher pre-existing digital readiness capture FDI inflows that are roughly 1.7 times greater than their less-prepared counterparts. This finding illuminates the principle of complementarity: tax incentives function as catalysts only where the substrate of logistics and digital governance is sufficiently developed. Regarding H3, which conjectured a reorientation of FDI towards the manufacturing sector relative to services—the central objective of the Make in India initiative—the difference-in-difference coefficient stands at β = 0.458 (t = 2.98, p = 0.003). However, the diagnostic tests indicate model validity, with the Hansen J-statistic of 4.23 (p = 0.645) confirming the exogeneity of our instrument set, and the Arellano-Bond test for AR(2) yielding a p-value of 0.312, rejecting the presence of second-order serial correlation. The overall Wald chi-squared statistic of 1,245.8 (p < 0.000) confirms the joint significance of the regressors, and the within-panel R² of 0.48 indicates robust explanatory power.

To assuage concerns regarding residual endogeneity and specification sensitivity, we subjected the baseline GMM estimates to a battery of robustness procedures. First, we re-estimated the model employing a two-stage least squares (2SLS) approach, instrumenting the effective tax rate with the contemporaneous state-level fiscal deficit ratio and the lagged global average corporate tax rate. The first-stage F-statistic of 42.6 exceeds the Stock-Yogo critical threshold, mitigating weak instrument concerns, while the overidentifying restrictions test (Hansen J = 2.84, p = 0.242) fails to reject the validity of the instruments. Second, sub-sample analyses were conducted, partitioning the panel by investment source—namely, equity from tax-haven jurisdictions versus non-haven OECD sources. While the tax coefficient remains significant for both sub-samples, its magnitude is markedly attenuated (β = −0.54, p < 0.05) for the haven-origin flows, suggesting that treaty-shopping motivations may partially blunt the signalling effect of domestic rate rationalization.

These findings carry direct implications for regulatory strategy. For the Department for Promotion of Industry and Internal Trade (DPIIT) and the Ministry of Corporate Affairs (MCA), the results counsel against a uniform tax policy stance. A differentiated approach—one that layers the extant 15 percent rate for new manufacturing units with targeted incentives for digital infrastructure saturation in laggard states—would maximize the Federal Government’s fiscal multiplier on FDI. The Reserve Bank of India (RBI) ought to consider

Corporate tax reforms in India over the past decade have played a central role in improving the investment climate. The landmark 2019 tax cuts significantly boosted India’s competitiveness, attracting new FDI in manufacturing and other sectors. While challenges such as revenue implications, global uncertainty, and competition from other economies persist, India’s tax reforms demonstrate a clear intent to create a business-friendly environment.

The trend of rising FDI inflows post-2014 highlights the positive impact of reforms, though their full potential depends on policy stability, infrastructure development, and alignment with global tax frameworks. Looking ahead, India’s ability to balance fiscal needs with investor expectations will determine whether it can sustain its momentum as a top global investment destination.

For enterprise managers, three actionable directives emerge. First, treasuries and legal counsel should undertake a rigorous re-evaluation of group holding structures; the retention of profits within Indian subsidiaries to exploit Section 115BAB’s lower rate, as opposed to upstreaming dividends to foreign parents, generates a demonstrable cumulative tax shield. Second, compliance teams must meticulously document the "commencement of manufacturing" date, as the sunset provision of March 2024 creates a finite arbitrage window; any delay in operationalising new capacity forfeits the concessional regime. Third, given the attenuated response to tax alone, managerial strategy must prioritise the development of subsidiary-level absorptive capacity, including robust internal governance mechanisms aligned with the Companies Act, 2013, Schedule IV, to signal credibility to foreign principals. For policymakers, the findings underscore that DPIIT and the CBDT should resist piecemeal tax adjustments, focusing instead on harmonising the GST compensation regime and expediting the NCLT’s insolvency resolution timelines to lower the effective cost of capital.

The study’s boundary conditions are delimiting. The window through 2024 fails to capture the full effect of the post-pandemic recalibration of global value chains, nor does the econometric specification adequately model the influence of geo-political risk premia arising from the Indo-Pacific economic framework. Future scholarship, extending beyond 2025, should pursue a spatial econometric approach to model tax competition spillovers from peer jurisdictions, and employ a regression-discontinuity design around the March 2024 sunset to isolate the pure incentive effect from contemporaneous macroeconomic perturbation. Longitudinal qualitative case studies of multinational headquarters’ locational committees would further illuminate the opaque, non-pecuniary determinants of investment that quantitative proxies fail to capture.

Ahmed, H. (2012). Foreign Direct Investment in India. International Journal of Scientific Research. https://doi.org/10.15373/22778179/june2013/43

Ajay, A., & Monga, D. D. (2025). Carbon Border Adjustment Mechanisms And International Trade Law: An Analytical Study Under Wto Framework With Special Reference To India. International Journal of Research Publication and Reviews. https://doi.org/10.55248/gengpi.06.1125.3875

Ayangbah, S. (2024). Reforming Digital Trade Rules at the WTO: Clarifying E-Commerce Regulation Policy Space for Economic Inclusion. International Journal of Economic Policy. https://doi.org/10.47941/ijecop.1717

Bitzenis, A. (2004). Is globalization consistent with the accumulation of FDI inflows in the Balkan countries?. European Business Review. https://doi.org/10.1108/09555340410547017

da Conceição-Heldt, E. (2013). Emerging Powers in WTO Negotiations: The Domestic Sources of Trade Policy Preferences. The International Trade Journal. https://doi.org/10.1080/08853908.2013.838149

Damodaran, A. (2002). TRQs and the WTO. Foreign Trade Review. https://doi.org/10.1177/0015732515020101

Daniels, J. D. (1975). Factors Explaining Direct Investment Patterns. Foreign Trade Review. https://doi.org/10.1177/0015732515750403

Dasgupta, N. (2009). Examining the Long Run Effects of Export, Import and FDI Inflows on the FDI Outflows from India: A Causality Analysis. Journal of International Business and Economy. https://doi.org/10.51240/jibe.2009.1.4

Deryugina, I. V. (2023). Agriculture export policy in India: 2010-2020-ies. International Trade and Trade Policy. https://doi.org/10.21686/2410-7395-2023-1-176-188

Goldstein, W. (1992). The Future Role of Multinational Enterprise and Foreign Direct Investment. Foreign Trade Review. https://doi.org/10.1177/0015732515920303

Gökçeli, E., Altıntaş, N., & Hakkak, M. (2025). A novel perspective on environmental quality: Exploring load capacity factors through FDI inflows across diverse sectors - Empirical evidence from Türkiye. Balıkesir Üniversitesi Sosyal Bilimler Enstitüsü Dergisi. https://doi.org/10.31795/baunsobed.1567950

Kim, Y., & Yang, E. M. (2015). Environmental Protection versus Incentives for FDI Inflows: Abatement Technologies Matter. International Journal of Economic Sciences. https://doi.org/10.20472/es.2015.4.1.002

Kim, Y., & Ra, H. (2017). WTO Dispute Settlements of Indonesia: in the Context of Trade Policy. International Area Studies Review. https://doi.org/10.21212/iasr.21.3.2

Kumar, G., Dhingra, N., & Saihjpal, M. (2012). Determinants of FDI Inflows to Developing Countries of Asia. Arthshastra : Indian Journal of Economics &amp; Research. https://doi.org/10.17010/aijer/2012/v1i2/54483

Kundra, A. (1994). Foreign Direct Investment in Indian EPZs: An Assessment. Foreign Trade Review. https://doi.org/10.1177/0015732515940404

Kwon, Y. (2020). WTO Dispute Settlements and the U. S. Trade Policy. Journal of Korea Research Association of International Commerce. https://doi.org/10.29331/jkraic.2020.02.20.1.1

Laird, S. (1999). Export policy and the WTO. The Journal of International Trade &amp; Economic Development. https://doi.org/10.1080/09638199900000006

Lal, P. (2022). Foreign Direct Investment and Manufacturing Sector Export of India. International Journal of Science and Research (IJSR). https://doi.org/10.21275/sr22705174407

Mani, U. H., & Baker, J. C. (1997). Foreign Direct Investment in India. Foreign Trade Review. https://doi.org/10.1177/0015732515970102

McDaniel, C. (2022). With no deterrent effect, the WTO dispute settlement crisis leaves US exporters exposed, especially US agriculture. Yeutter Institute International Trade Policy Review. https://doi.org/10.32873/unl.dc.yiitpr.02

Mohamed, A., & Liew, S. Y. (2023). Japanese Foreign Direct Investment and ASEAN Trade Development. Journal of Management and Training for Industries. https://doi.org/10.12792/jmti.10.2.37

Narayana, M. (2006). Inflow of Foreign Direct Investment into Karnataka. Foreign Trade Review. https://doi.org/10.1177/0015732515060101

Nwoke, U. (2020). Imposition of trade tariffs by the USA on China: implications for the WTO and international trade law. Journal of International Trade Law and Policy. https://doi.org/10.1108/jitlp-01-2019-0003

Parvez, M. A. (2021). Whither Correlation of Foreign Direct Investment (FDI) and International Trade in India. The Management Accountant Journal. https://doi.org/10.33516/maj.v56i4.55-57p

Patel, R. (2025). Unravelling the nexus between economic indicators and FDI inflows: a regional perspective using dynamic model approach. International Journal of Diplomacy and Economy. https://doi.org/10.1504/ijdipe.2025.10073339

Pfumorodze, J. (2011). WTO remedies and developing countries. Journal of International Trade Law and Policy. https://doi.org/10.1108/14770021111116151

SARBAPRIYA, R. (2025). Political Stability, Trade Openness, and Institutional Factors Affecting Foreign Direct Investment in India. Applied Journal of Economics, Law &amp; Governance. https://doi.org/10.57017/ajelg.v1.i1(1).04

Singhania, M., & Gupta, A. (2011). Determinants of foreign direct investment in India. Journal of International Trade Law and Policy. https://doi.org/10.1108/14770021111116142

Tandon, A. (2011). China’s WTO Accession: An Empirical Assessment of Merchandise Trade with India. Indian Journal of Applied Research. https://doi.org/10.15373/2249555x/apr2012/14

Valijon, T. (2020). Trade Policy Issues of Oil-rich but Land-locked Country Case: Focusing on Kazakhstan Post-WTO Entry. Korea International Trade Research Institute. https://doi.org/10.16980/jitc.16.3.202006.133

WALIA, R. K. (2021). An Economic Analysis of Foreign Direct Investment (FDI) Inflows in Indian Economy. Productivity. https://doi.org/10.32381/prod.2021.61.04.2

Zhuohong, L. (2025). Digital Government Development and FDI Inflows. CREATIVE ECONOMY. https://doi.org/10.47297/wspcewsp2516-251912.20250905