Accounting for the profits of multinational enterprises: Double counting and misattribution of foreign affiliate income

Given the perception that multinational enterprises (MNEs) engage in extensive tax planning, ending base erosion and profit shifting activity is a priority on many national agendas. Yet the actual level of such activity is subject to debate. In this paper, we provide guidance on how to accurately measure country-level MNE income using the datasets commonly used in research on profit shifting. This issue is of global concern, as any economic data that reports profits by jurisdiction must use an established accounting method to report the activity of the MNEs’ indirectly owned foreign affiliates. We explain how the accounting method could lead a researcher to double count income or to attribute it to the wrong jurisdiction. Such errors not only affect measures of the MNEs’ country-level profits, but also bias researchers’ estimates of the sensitivity of income to taxes. Although we focus our analysis on data from the U.S. Bureau of Economic Analysis (BEA), we illustrate the consequences of such mismeasurement across a variety of studies relying on a variety of data sources.