全球利润转移的证据以及跨时间的全球证据

Fotis Delis, Manthos D. Delis, Luc Laeven,Steven Ongena Abstract:We provide estimates of profit shifting for over 2 million firm-year observations in100 countries over the period 2009–2020. Employing nonparametric estimation techniqueswithin a mainstay model of profit shifting, we examine how the profits of both parent andsubsidiary firms within a multinational group respond to marginal changes in the composite taxindicator. The key advantage of this approach is that it yields firm-year estimates of profitshifting. Multinational firms engage in extensive profit shifting by maintaining affiliates in low-tax countries and zero-tax havens. Multinational groups with an ultimate tax-haven ownerexhibit the largest profit response to tax incentives. Our new database opens important avenuesfor analyzing the sources and effects of profit shifting.Keywords:Profit shifting; multinational enterprises; nonparametric estimation; tax arbitrage;global sampleJEL Classification:F23; H25; H26; H32; M41ECB Working Paper Series No 30711 Executive summary:Large global companies commonly engage in tax planning strategies tomove their profits from high-tax countries to low-tax (or no-tax) countries to reduce the amountof taxes they pay. Such “shifting” of profits across borders within multinational enterprises isknown as “profit shifting”. Such profit-shifting practices cost governments billions of USdollars in lost tax revenues annually. This has triggered policy changes from governments tocontain this practice. The most prominent policy change is the June 2021 agreement among G7finance ministers to seek a minimum global corporate tax rate of at least 15 percent, whichfollowed the OECD’s Base Erosion and Profit Shifting (BEPS) initiative to limit profit shifting.In this paper, we provide global estimates of profit shifting using firm level data. Most existingstudies either focus only on profit shifting within or across firms, and do not consider variationin profit shifting over time. We use the most complete sample of firms and their foreignsubsidiaries to date to estimate profit shifting both within and across firms and measure shiftsin such patters over time. In total, our dataset covers more than 2 million firm-year observationsof around half a million firms from across 100 different countries over the period 2009–2020.Our new estimates of profit shifting enable us to trace the origin of profit shifting and to betteridentify the underlying drivers of profit shifting. Moreover, our time-varying estimates of profitshifting, along with dynamic information on the corporate ownership links, allow us to identifythe physical routes of profit shifting via intermediate countries. Specifically, we determine taxroutes involving strings of multiple countries and identify the industries and ownershipstructures involved. Thus, we offer a more detailed view of how firms conduct profit shiftingcompared to simply specifying the origin and destination countries. This offers the informationrequired to assess the effects of specific BEPS actions and bilateral agreements. Finally, withour richer dataset we obtain more comprehensive estimates of profit shifting that indicate thatthe amount of profits shifted globally exceeds the estimates obtained to date in the literatureusing firm level data.To obtain firm-year estimates of profit shifting we estimates a standard model of profit shiftingusing local regression techniques. This technique differs from the more widely used method ofordinary least squares (OLS) because it does not assume that the relationship between companyearnings and tax differences is constant over time. Instead, it creates sliding windows ofobservations around each data point, allowing us to estimate the response of firm profits to thetax incentive by considering nearby observations. Estimation of the local regression entailsrepeating this approach for each data point in our dataset, resulting in a profit-shifting estimatefor each firm-year observation.We find that profit shifting is heavily concentrated in several industries, such as thepharmaceutical, petroleum, and information technology industries engage in the greatest profitshifting. At a global level, we find that profit shifting increased over time from around 300billion US dollars in 2009 to more than 700 billion US dollars in 2017. Delving deeper into theglobal routes of profit shifting, we find that a substantial amount of profit shifting flows throughtax havens and low-tax jurisdictions, such as Bermuda, the British Virgin Islands, the CaymanIslands, the United Arab Emirates (UAE), and Ireland. Our more comprehensive estimates ofprofit-shifting obtained using firm-level data are broadly in line with those obtained based onaggregate data.ECB Working Paper Series No 30712 1. IntroductionTax-motivated profit shifting refers to the tax planning strategies of multinational enterprises(MNEs) and their “shifting” of profits from parent companies or subsidiaries located in