Billions of dollars in corporate tax breaks have failed to increase business investment, according to a study to be released today by Citizens for Tax Justice, a self-styled public-interest group.

A survey of 238 large companies found no correlation between low tax payments and investment.

It found that 58 profitable, nonfinancial companies that paid no taxes from 1981 to 1983 cut their investment by 19.3 percent during the same period.

At the same time, the 50 companies surveyed with the highest tax rates raised their investment by 4.3 percent.

The 238 companies surveyed, all profitable, had an average effective tax rate of 14.3 percent, based on their annual reports. The corporate tax rate is 46 percent, although effective tax rates usually are much lower because of deductions, credits and other provisions of the tax code.

Over the three-year period, the companies reduced investment 15.5 percent and raised dividends 17 percent, the report said.

"Our study examines how the corporate rhetoric advocating ever-expanding tax concessions stands up against actual corporate behavior and finds that the 'tax incentives' have been a colossal failure," said Robert S. McIntyre, tax-policy director for the group, which is funded principally by labor unions.

Instead of responding to tax incentives, firms decide whether to invest based on consumer demand, the study concluded. Companies invest "only when they need new plant and equipment to produce products they can sell to consumers. When consumers don't spend money, plants are idled and new investment drops."

The 1981 tax cut that President Reagan pushed through Congress contained a host of business tax breaks, including accelerated depreciation write-offs, a tax credit for research and development and expanded sales of tax benefits from companies that couldn't use them to firms that could.

At the time, business groups said the law would create a flood of investment. It was followed, however, by a deep recession from July 1981 to November 1982 that cut investment and raised the unemployment rate.

McIntyre's report did not adjust for that recession and thus distorted its results, said Gordon Richards, an economist with the National Association of Manufacturers. And by looking at individual companies over the short term rather than at aggregate figures in the long run, the report doesn't reflect nationwide trends, he said.

"Econometric studies have found that investment contracted during the recession, but that without accelerated depreciation it would have decreased by a greater magnitude," Richards said. "Even if we assume that investment is dominated by the business cycle, other factors such as corporate tax rates and the treatment of depreciation are statistically significant in accounting for changes in investment over time."