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Home or Away? Profit Shifting with Territorial Taxation

Author

Listed:
  • Dominika Langenmayr
  • Ms. Li Liu

Abstract

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.

Suggested Citation

  • Dominika Langenmayr & Ms. Li Liu, 2022. "Home or Away? Profit Shifting with Territorial Taxation," IMF Working Papers 2022/177, International Monetary Fund.
    • Handle: RePEc:imf:imfwpa:2022/177
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    2. Vito Amendolagine & Randolph Luca Bruno & Maria Cipollina & Gianluigi De Pascale, 2025. "Minimum global tax: winners and losers in the race for mergers and acquisitions," Eurasian Business Review, Springer;Eurasia Business and Economics Society, vol. 15(4), pages 1249-1278, December.
    3. Yang, JinHyuk & Kang, Youngho, 2023. "Effects of home country tax reform on FDI inflows to South Korea: A synthetic control method approach," Economics Letters, Elsevier, vol. 225(C).
    4. Katarzyna A. Bilicka & Michael P. Devereux & İrem Güçeri, 2024. "Tax Policy, Investment and Profit Shifting," NBER Working Papers 33132, National Bureau of Economic Research, Inc.
    5. Peter H. Egger & Pinar Kaynak Gunes & Benedikt Zoller-Rydzek, 2024. "Multinational and exporter wage premia: evidence from southeastern Europe and a panel multiple-treatments approach," Empirical Economics, Springer, vol. 66(6), pages 2451-2470, June.
    6. Zhang, Jianhong & Jiang, Jiangang, 2024. "Investment deregulation and innovation performance of Chinese private firms," Journal of Financial Stability, Elsevier, vol. 70(C).
    7. Gurshev, Oleg, 2025. "From Russia with love: Empirical evidence on affiliate profitability under sanctions and capital flight across borders," Economic Systems, Elsevier, vol. 49(3).
    8. Xingyu Lu & Tong Qi & Wenjing Xie, 2023. "Earnings Management of Chinese Listed Multinational Corporations," China & World Economy, Institute of World Economics and Politics, Chinese Academy of Social Sciences, vol. 31(6), pages 179-206, November.
    9. Xue, Mantian & Yan, Ge, 2025. "The impact of 2008 tax reform on profit shifting of foreign enterprises in China," Structural Change and Economic Dynamics, Elsevier, vol. 73(C), pages 345-353.

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    JEL classification:

    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business

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