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Could Country-by-Country Reporting Increase Profit Shifting?

Author

Listed:
  • Ruby Doeleman
  • Dominika Langenmayr
  • Dirk Schindler

Abstract

Since 2016, Country-by-Country reporting has provided tax authorities with detailed information about multinationals’ worldwide activities. It has been hailed as a game-changer for corporate taxation, enabling tax authorities to target multinational firms with high profits in tax havens. We model Country-by-Country reporting as increasing both tax planning and audit costs for profit-shifting multinationals, where the latter costs depend on the share of profits held in tax havens. Then, Country-by-Country reporting makes shifting profits from a high-tax country to a tax haven relatively more attractive than shifting from a low-tax country to a tax haven—a substitution effect. Thus, while the total amount of profits shifted to the tax haven decreases, profit shifting from high-tax affiliates may increase relative to the situation without Country-by-Country reporting. We confirm these changes in profit-shifting patterns using a staggered difference-in-differences design. The opposing effects for low-tax and high-tax countries also help explaining the mixed findings of previous empirical studies on Country-by-Country reporting.

Suggested Citation

  • Ruby Doeleman & Dominika Langenmayr & Dirk Schindler, 2024. "Could Country-by-Country Reporting Increase Profit Shifting?," CESifo Working Paper Series 11464, CESifo.
  • Handle: RePEc:ces:ceswps:_11464
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    References listed on IDEAS

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    1. Haufler, Andreas & Runkel, Marco, 2012. "Firms' financial choices and thin capitalization rules under corporate tax competition," European Economic Review, Elsevier, vol. 56(6), pages 1087-1103.
    2. Gresik, Thomas A. & Schindler, Dirk & Schjelderup, Guttorm, 2017. "Immobilizing corporate income shifting: Should it be safe to strip in the harbor?," Journal of Public Economics, Elsevier, vol. 152(C), pages 68-78.
    3. Sun, Liyang & Abraham, Sarah, 2021. "Estimating dynamic treatment effects in event studies with heterogeneous treatment effects," Journal of Econometrics, Elsevier, vol. 225(2), pages 175-199.
    4. Kevin Markle, 2016. "A Comparison of the Tax†Motivated Income Shifting of Multinationals in Territorial and Worldwide Countries," Contemporary Accounting Research, John Wiley & Sons, vol. 33(1), pages 7-43, March.
    Full references (including those not matched with items on IDEAS)

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    More about this item

    Keywords

    country-by-country-reporting; profit shifting; anti-tax-avoidance rules;
    All these keywords.

    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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