Analysis of information sources in references of the Wikipedia article "Base erosion and profit shifting" in English language version.
The U.S. didn't sign the groundbreaking tax treaty inked by 68 [later 70] countries in Paris June 7 [2017] because the U.S. tax treaty network has a low degree of exposure to base erosion and profit shifting issues", a U.S. Department of Treasury official said at a transfer pricing conference co–sponsored by Bloomberg BNA and Baker McKenzie in Washington
Finally, we find that US firms with operations in some tax haven countries have higher federal tax rates on foreign income than other firms. This result suggests that in some cases, tax haven operations may increase US tax collections at the expense of foreign country tax collections.
IP onshoring is something we should be expecting to see much more of as we move towards the end of the decade. Buckle up!
The United Kingdom has 122 bilateral, comprehensive, double taxation conventions in force. It remains the largest number of tax treaties of any one country in the world. The United Kingdom may no longer be the world leader in manufacturing cars, or in playing football... however we are still the leading country in the world in negotiating double taxation conventions.
Cutting the official corporate tax rate to 20 per cent from its present 35 per cent — a level that US companies say hurts them in global competition — would leave companies short of the 15 per cent Mr Trump promised as a candidate
{{cite journal}}: Cite journal requires |journal= (help)Appendix Table 2: Tax Havens
Table 2: Shifted Profits: Country–by–Country Estimates (2015)
Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions and the Sources of Those Jurisdictions
The major problem, it says, has been the decision by the Organisation in 2013 when it came up with its standard on country–by–country reporting (CBCR) to give into intense lobbying, largely from US multinationals, and place limits on access to the data.
New Gabriel Zucman study claims State shelters more multinational profits than the entire Caribbean
Of the wider tax environment, O'Rourke thinks the OECD base-erosion and profit-shifting (BEPS) process is "very good" for Ireland: "If BEPS sees itself to a conclusion, it will be good for Ireland."
In a policy note, the Washington-based think tank said US proposals to ensure companies pay taxes based on where they make their sales were gathering momentum and already had the backing of Brazil, China, India, and other emerging economies. Currently, the tax big companies such as Google and Facebook pay largely depends on where their assets, employees and head offices are located.
Ireland solidifies its position as the #1 tax haven," Zucman said on Twitter. "U.S. firms book more profits in Ireland than in China, Japan, Germany, France & Mexico combined. Irish tax rate: 5.7%.
A key architect [for Apple] was Baker McKenzie, a huge law firm based in Chicago. The firm has a reputation for devising creative offshore structures for multinationals and defending them to tax regulators. It has also fought international proposals for tax avoidance crackdowns.
With a conservatively estimated annual revenue loss of USD 100 to 240 billion, the stakes are high for governments around the world. The impact of BEPS on developing countries, as a percentage of tax revenues, is estimated to be even higher than in developed countries.
..for US multinationals, the real explosion in profit shifting began in the 1990s. At this point, a 'mere' 5–10% of global profits were declared away from the jurisdictions of the underlying real economic activity. By the early 2010s, that had soared to 25–30% of global profits, with an estimated revenue loss of around $130 billion a year..
Our key findings demonstrate that there is a strong correlation and causal link between the size of an MNE's tax haven network and their use of the Big 4
Second, it confirms (once again) that the OECD BEPS process has failed.
Figure I: U.S. Chamber International IP Index 2018, Overall Scores
This political capture produces one of the great offshore paradoxes: these zones of ultra–freedom are often highly repressive places, wary of scrutiny and intolerant of criticism.
It focuses particularly on the dominant approach within the economics literature on income shifting, which dates back to Hines and Rice (1994) and which we refer to as the "Hines–Rice" approach.
Intellectual property (IP) has become the leading tax-avoidance vehicle.
Lower foreign tax rates entail smaller credits for foreign taxes and greater ultimate U.S. tax collections (Hines and Rice, 1994). Dyreng and Lindsey (2009), offer evidence that U.S. firms with foreign affiliates in certain tax havens pay lower foreign taxes and higher U.S. taxes than do otherwise-similar large U.S. companies
Germany taxes only 5% of the active foreign business profits of its resident corporations. [..] Furthermore, German firms do not have incentives to structure their foreign operations in ways that avoid repatriating income. Therefore, the tax incentives for German firms to establish tax haven affiliates are likely to differ from those of U.S. firms and bear strong similarities to those of other G-7 and OECD firms.
We identify 41 countries and regions as tax havens for the purposes of U. S. businesses. Together the seven tax havens with populations greater than one million (Hong Kong, Ireland, Liberia, Lebanon, Panama, Singapore, and Switzerland) account for 80 percent of total tax haven population and 89 percent of tax haven GDP.
The U.S. didn't sign the groundbreaking tax treaty inked by 68 [later 70] countries in Paris June 7 [2017] because the U.S. tax treaty network has a low degree of exposure to base erosion and profit shifting issues", a U.S. Department of Treasury official said at a transfer pricing conference co–sponsored by Bloomberg BNA and Baker McKenzie in Washington
Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions and the Sources of Those Jurisdictions
We identify 41 countries and regions as tax havens for the purposes of U. S. businesses. Together the seven tax havens with populations greater than one million (Hong Kong, Ireland, Liberia, Lebanon, Panama, Singapore, and Switzerland) account for 80 percent of total tax haven population and 89 percent of tax haven GDP.
Such profit shifting leads to a total annual revenue loss of $200 billion globally
U.S. companies are the most aggressive users of profit-shifting techniques, which often relocate paper profits without bringing jobs and wages, according to the study by economists Thomas Torslov and Ludvig Wier of the University of Copenhagen and Gabriel Zucman of the University of California, Berkeley