Home Or Away? Profit Shifting with Territorial Taxation

Home Or Away? Profit Shifting with Territorial Taxation

Author: Dominika Langenmayr

Publisher: International Monetary Fund

Published: 2022-09-09

Total Pages: 38

ISBN-13:

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In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that the profitability of UK subsidiaries in low-tax countries increased after the reform compared to subsidiaries of non-UK multinationals in the same countries by an average of 2 percentage points. This increase in profit shifting also leads to increases in measured productivity of the foreign affiliates of UK multinationals of between 5 and 9 percent.


Book Synopsis Home Or Away? Profit Shifting with Territorial Taxation by : Dominika Langenmayr

Download or read book Home Or Away? Profit Shifting with Territorial Taxation written by Dominika Langenmayr and published by International Monetary Fund. This book was released on 2022-09-09 with total page 38 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that the profitability of UK subsidiaries in low-tax countries increased after the reform compared to subsidiaries of non-UK multinationals in the same countries by an average of 2 percentage points. This increase in profit shifting also leads to increases in measured productivity of the foreign affiliates of UK multinationals of between 5 and 9 percent.


Where Does Multinational Profit Go with Territorial Taxation?

Where Does Multinational Profit Go with Territorial Taxation?

Author: Dominika Langenmayr

Publisher:

Published: 2020

Total Pages:

ISBN-13:

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In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that profits of UK subsidiaries in low-tax countries increased after the reform compared to subsidiaries of non-UK multinationals in the same countries, by an average of 2.1 percentage points. The increase in profit shifting also leads to increases in measured productivity of the foreign affiliates of UK multinationals of between 5 and 9 percent.


Book Synopsis Where Does Multinational Profit Go with Territorial Taxation? by : Dominika Langenmayr

Download or read book Where Does Multinational Profit Go with Territorial Taxation? written by Dominika Langenmayr and published by . This book was released on 2020 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2009, the United Kingdom abolished the taxation of profits earned abroad and introduced a territorial tax system. Under the territorial system, firms have strong incentives to shift profits abroad. Using a difference-in-differences research design, we show that profits of UK subsidiaries in low-tax countries increased after the reform compared to subsidiaries of non-UK multinationals in the same countries, by an average of 2.1 percentage points. The increase in profit shifting also leads to increases in measured productivity of the foreign affiliates of UK multinationals of between 5 and 9 percent.


Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK

Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK

Author: Ms.Li Liu

Publisher: International Monetary Fund

Published: 2018-01-13

Total Pages: 49

ISBN-13: 1484337700

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In 2009, the United Kingdom changed from a worldwide to a territorial tax system, abolishing dividend taxes on foreign repatriation from many low-tax countries. This paper assesses the causal effect of territorial taxation on real investments, using a unique dataset for multinational affiliates in 27 European countries and employing the difference-in-difference approach. It finds that the territorial reform has increased the investment rate of UK multinationals by 15.7 percentage points in low-tax countries. In the absence of any significant investment reduction elsewhere, the findings represent a likely increase in total outbound investment by UK multinationals.


Book Synopsis Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK by : Ms.Li Liu

Download or read book Where Does Multinational Investment Go with Territorial Taxation? Evidence from the UK written by Ms.Li Liu and published by International Monetary Fund. This book was released on 2018-01-13 with total page 49 pages. Available in PDF, EPUB and Kindle. Book excerpt: In 2009, the United Kingdom changed from a worldwide to a territorial tax system, abolishing dividend taxes on foreign repatriation from many low-tax countries. This paper assesses the causal effect of territorial taxation on real investments, using a unique dataset for multinational affiliates in 27 European countries and employing the difference-in-difference approach. It finds that the territorial reform has increased the investment rate of UK multinationals by 15.7 percentage points in low-tax countries. In the absence of any significant investment reduction elsewhere, the findings represent a likely increase in total outbound investment by UK multinationals.


A Comparison of the Tax-Motivated Income Shifting of Multinationals in Territorial and Worldwide Countries

A Comparison of the Tax-Motivated Income Shifting of Multinationals in Territorial and Worldwide Countries

Author: Kevin Markle

Publisher:

Published: 2015

Total Pages: 40

ISBN-13:

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This paper tests for differences in the tax-motivated income shifting behaviors of multinationals subject to different systems of taxing foreign earnings. I find that multinationals subject to territorial tax regimes shift more income than those subject to worldwide tax regimes, but that the difference in shifting is not statistically different when the worldwide firms can defer repatriation of the shifted income. In additional tests, I find that all firms have cash trapped in foreign countries by withholding taxes on dividends and that worldwide firms (specifically those domiciled in the U.S.) have cash trapped by the residual home country tax due on repatriation of foreign dividends.


Book Synopsis A Comparison of the Tax-Motivated Income Shifting of Multinationals in Territorial and Worldwide Countries by : Kevin Markle

Download or read book A Comparison of the Tax-Motivated Income Shifting of Multinationals in Territorial and Worldwide Countries written by Kevin Markle and published by . This book was released on 2015 with total page 40 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper tests for differences in the tax-motivated income shifting behaviors of multinationals subject to different systems of taxing foreign earnings. I find that multinationals subject to territorial tax regimes shift more income than those subject to worldwide tax regimes, but that the difference in shifting is not statistically different when the worldwide firms can defer repatriation of the shifted income. In additional tests, I find that all firms have cash trapped in foreign countries by withholding taxes on dividends and that worldwide firms (specifically those domiciled in the U.S.) have cash trapped by the residual home country tax due on repatriation of foreign dividends.


OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS

OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS

Author: OECD

Publisher: OECD Publishing

Published: 2017-07-27

Total Pages: 104

ISBN-13: 9264278796

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This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).


Book Synopsis OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS by : OECD

Download or read book OECD/G20 Base Erosion and Profit Shifting Project Neutralising the Effects of Branch Mismatch Arrangements, Action 2 Inclusive Framework on BEPS written by OECD and published by OECD Publishing. This book was released on 2017-07-27 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: This 2017 report sets out recommendations for branch mismatch rules that would bring the treatment of these structures into line with the treatment of hybrid mismatch arrangements as set out in the 2015 Report on Neutralising the Effects of Hybrids Mismatch Arrangements (Action 2 Report).


Corporate Profit Shifting

Corporate Profit Shifting

Author: Dorian L. Peters

Publisher:

Published: 2015

Total Pages: 171

ISBN-13: 9781634837750

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Congress and the Obama Administration have expressed interest in addressing multinational corporations' ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. This book is intended to assist Congress as it considers what, if any, action to curb profit shifting. This book discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. In addition, this book addresses tax havens; basic concepts and policy issues of U.S. international corporate taxation; and reforms of U.S. international taxation.


Book Synopsis Corporate Profit Shifting by : Dorian L. Peters

Download or read book Corporate Profit Shifting written by Dorian L. Peters and published by . This book was released on 2015 with total page 171 pages. Available in PDF, EPUB and Kindle. Book excerpt: Congress and the Obama Administration have expressed interest in addressing multinational corporations' ability to shift profits into low- and no-tax countries with little corresponding change in business operations. Several factors appear to be driving this interest. Economists have estimated that profit shifting results in significant tax revenue losses annually, implying that reducing the practice could help address deficit and debt concerns. Profit shifting and base erosion are also believed to distort the allocation of capital as investment decisions are overly influenced by taxes. Fairness concerns have also been raised. If multinational corporations can avoid or reduce their taxes, other taxpayers (including domestically focused businesses and individuals) may perceive the tax system as unfair. At the same time, policymakers are also concerned that American corporations could be unintentionally harmed if careful consideration is not given to the proper way to reduce profit shifting. This book is intended to assist Congress as it considers what, if any, action to curb profit shifting. This book discusses the methods used for shifting profits only to the extent that it is necessary for interpreting the data or discussing policy options. In addition, this book addresses tax havens; basic concepts and policy issues of U.S. international corporate taxation; and reforms of U.S. international taxation.


International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots

International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots

Author: Sebastian Beer

Publisher: International Monetary Fund

Published: 2018-07-23

Total Pages: 45

ISBN-13: 148436399X

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This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.


Book Synopsis International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots by : Sebastian Beer

Download or read book International Corporate Tax Avoidance: A Review of the Channels, Magnitudes, and Blind Spots written by Sebastian Beer and published by International Monetary Fund. This book was released on 2018-07-23 with total page 45 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper reviews the rapidly growing empirical literature on international tax avoidance by multinational corporations. It surveys evidence on main channels of corporate tax avoidance including transfer mispricing, international debt shifting, treaty shopping, tax deferral and corporate inversions. Moreover, it performs a meta analysis of the extensive literature that estimates the overall size of profit shifting. We find that the literature suggests that, on average, a 1 percentage-point lower corporate tax rate will expand before-tax income by 1 percent—an effect that is larger than reported as the consensus estimate in previous surveys and tends to be increasing over time. The literature on tax avoidance still has several unresolved puzzles and blind spots that require further research.


A Destination-Based Allowance for Corporate Equity

A Destination-Based Allowance for Corporate Equity

Author: Shafik Hebous

Publisher: International Monetary Fund

Published: 2018-11-08

Total Pages: 26

ISBN-13: 1484381904

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Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.


Book Synopsis A Destination-Based Allowance for Corporate Equity by : Shafik Hebous

Download or read book A Destination-Based Allowance for Corporate Equity written by Shafik Hebous and published by International Monetary Fund. This book was released on 2018-11-08 with total page 26 pages. Available in PDF, EPUB and Kindle. Book excerpt: Following renewed academic and policy interest in the destination-based principle for taxing profits—particularly through a destination-based cash flow tax (DBCFT)—this paper studies other forms of efficient destination-based taxes. Specifically, it analyzes the Destination-Based Allowance for Corporate Equity (DBACE) and Allowance for Corporate Capital (DBACC). It describes adjustments that are required to turn an origin into a destination-based versions of these taxes. These include adjustments to capital and equity, which are additional to the border adjustments needed under a DBCFT. The paper finds that the DBACC and DBACE reduce profit shifting and tax competition, but cannot fully eliminate them, with the DBACE more sensitve than the DBACC. Overall, given the potential major political cost of switching from an origin to a destination-based tax system, we conclude that advantages of the DBCFT are likely to outweigh the transitional advantages of the DBACE/DBACC.


Reform of U.S. International Taxation

Reform of U.S. International Taxation

Author: Jane Gravelle

Publisher:

Published: 2015

Total Pages: 0

ISBN-13:

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This report describes and assesses the principal prescriptions that have been offered for broad reform of the international system. It begins with an overview of current law and possible revisions. It then sets the framework for considering economic efficiency as well as tax shelter activities. Finally, it reviews alternative approaches to revision in light of those issues.


Book Synopsis Reform of U.S. International Taxation by : Jane Gravelle

Download or read book Reform of U.S. International Taxation written by Jane Gravelle and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report describes and assesses the principal prescriptions that have been offered for broad reform of the international system. It begins with an overview of current law and possible revisions. It then sets the framework for considering economic efficiency as well as tax shelter activities. Finally, it reviews alternative approaches to revision in light of those issues.


A Firm Lower Bound: Characteristics and Impact of Corporate Minimum Taxation

A Firm Lower Bound: Characteristics and Impact of Corporate Minimum Taxation

Author: Aqib Aslam

Publisher: International Monetary Fund

Published: 2021-06-08

Total Pages: 50

ISBN-13: 1513561073

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This paper examines the role of minimum taxes and attempts to quantify their impact on economic activity. Minimum taxes can be effective at shoring up the corporate tax base and enhancing the perceived equity of the tax system, potentially motivating broader taxpayer compliance. Where political and administrative constraints prevent reforms to the standard corporate income tax, a minimum tax can help mitigate base erosion from excessive tax incentives and avoidance. Using a new panel dataset that catalogues changes in minimum tax regimes over time around the world, firm-level analysis suggests that the introduction or reform of a minimum tax is associated with an increase in the average effective tax rate of just over 1.5 percentage points with respect to turnover and of around 10 percent with respect to operating income. Minimum taxes based on modified corporate income lead to the largest increases in effective tax rates, followed by those based on assets and turnover.


Book Synopsis A Firm Lower Bound: Characteristics and Impact of Corporate Minimum Taxation by : Aqib Aslam

Download or read book A Firm Lower Bound: Characteristics and Impact of Corporate Minimum Taxation written by Aqib Aslam and published by International Monetary Fund. This book was released on 2021-06-08 with total page 50 pages. Available in PDF, EPUB and Kindle. Book excerpt: This paper examines the role of minimum taxes and attempts to quantify their impact on economic activity. Minimum taxes can be effective at shoring up the corporate tax base and enhancing the perceived equity of the tax system, potentially motivating broader taxpayer compliance. Where political and administrative constraints prevent reforms to the standard corporate income tax, a minimum tax can help mitigate base erosion from excessive tax incentives and avoidance. Using a new panel dataset that catalogues changes in minimum tax regimes over time around the world, firm-level analysis suggests that the introduction or reform of a minimum tax is associated with an increase in the average effective tax rate of just over 1.5 percentage points with respect to turnover and of around 10 percent with respect to operating income. Minimum taxes based on modified corporate income lead to the largest increases in effective tax rates, followed by those based on assets and turnover.