Taxing Capital in a Globalized World: The Effects of Automatic Information Exchange

In the second half of the 2010s more than 100 countries — including all large offshore financial centers — started to automatically exchange bank information with foreign tax authorities. This informational big-bang marks a break with the situation of offshore bank secrecy that prevailed before. We study its effects on tax compliance by analyzing the universe of information reports sent by foreign banks to Danish authorities, matched to population-wide micro-data on income, wealth, and cross-border bank transfers.

In response to the automatic exchange of bank information, tax evaders may repatriate previously undeclared offshore wealth, they may start to self-report offshore income to the tax authorities, or the tax authorities may detect their evasion in audits that use the new information reports.

Using a variety of research designs, we find large compliance effects along all these margins, with the largest response coming from repatriation of wealth. Overall we estimate that the automatic exchange of bank information has closed about 70% of the offshore tax gap.

These results highlight the power of international cooperation to improve tax compliance: tax evasion is not a law of nature in a globalized world.

Mapping the global geography of shell companies

This note examines the global prevalence and distribution of shell companies, which are often used for illicit financial activities like tax evasion. Using business registry data for over 200 jurisdictions, including individual US states, we construct an indicator of shell company prevalence based on the number of registered companies per capita. We find that known tax havens like the British Virgin Islands and the Cayman Islands have extremely high rates of company presence per adult. Zooming in on Europe reveals Estonia as a lesser-known host for shell companies, besides flagging known conduit countries like Luxembourg and Cyprus. A unique decomposition of US states also shows Delaware and Wyoming are potentially hosting a large number of shell companies. Indicative for the role of shell companies in international tax evasion, our shell company prevalence indicator correlates with jurisdiction characteristics catering tax evasion, such as low corporate tax rate and aggressive tax treaties.

Consumption Taxes and Corporate Income Taxes: Evidence from Place-Based VAT

Using a quasi-experimental setting, we document that corporations decrease declared profits and corporate income taxes in response to an increase in the VAT rate. In an attempt to raise tax revenue during the Greek economic crisis, a 16% VAT rate, which existed for historicopolitical reasons in Greek islands, was harmonised to the national 24% rate. We combine tax filings with Orbis and ICAP data that enable us to geolocate corporations and to construct comparable groups based on locations in or out of the preferential rate. Counteracting the reform’s intended effect, declared profits decreased by 28% and corporate income taxes by 34% on a permanent basis. Macroeconomic factors and a fall in reported revenue cannot fully explain this decrease. Pervasive tax evasion in the Greek islands, where corporations might have an opportunity to adjust profits, offers a plausible explanation of the magnitude of responses.

Global Tax Evasion Report 2024

Over the last 10 years, governments have launched major initiatives to reduce international tax evasion. These efforts include the creation of a new form of international cooperation long deemed utopian – an automatic, multilateral exchange of bank information in force since 2017 and applied by more than 100 countries in 2023 – and a landmark international agreement on a global minimum tax for multinational corporations, endorsed by more than 140 countries and territories in 2021.

Yet despite the importance of these developments, little is known about the effects of these new policies. Is global tax evasion falling or rising? Are new issues emerging, and if so, what are they? These questions are of tremendous importance in a context of rising income and wealth inequality, high public debt in the post-Covid-19 context, and large government revenue needs for addressing climate change and for funding health care, education, and public infrastructure.

This report addresses these issues thanks to an unprecedented international research collaboration and major data improvements. Prepared by the staff of the EU Tax Observatory – a research laboratory created in 2021 with unique expertise on international tax issues – this report summarizes work conducted by more than 100 researchers all over the world, often in partnership with tax administrations. This work leverages the availability of new data on the activities of multinational companies (such as country-by-country reports) and the offshore wealth of households (from the automatic exchange of bank information) created by the policy initiatives of the last decade. This report is the first systematic attempt at taking stock of this informational big bang.

We should make it clear at the outset that we do not restrict this report to the study of tax evasion in a narrow sense of fraud. Nor do we cover all forms of evasion, far from it. Our focus is on the issues that have been the focus of international policymaking over the last decade, the challenges posed by globalization for the taxation of multinational companies and high-net-worth individuals. Some of the practices we cover are clearly illegal – such as failing to report income earned on offshore bank accounts. Others are in a legal grey zone between avoidance and evasion – such as shifting profit to shell companies with no economic substance. Others are clearly legal, such as moving abroad to benefit from special tax regimes designed to attract wealthy individuals. All, however, allow the economic actors who have most benefited from globalization to reduce their tax rates to even lower levels, reducing government revenue, and increasing inequality. What is at stake in all cases is the question of the social sustainability of globalization and of modern tax systems.

We uncover positive evolution worth celebrating, but also setbacks, and major issues that remain unaddressed.

  • First, offshore tax evasion by wealthy individuals has shrunk. Thanks to the automatic exchange of bank information, we estimate that offshore tax evasion has declined by a factor of about three over the last 10 years. This success shows that rapid progress can be made against tax evasion if there is the political will to do so.
  • Second, the global minimum tax of 15% on multinationals, which raised high hopes in 2021, has been dramatically weakened. Initially expected to increase global corporate tax revenues by close to 10%, a growing list of loopholes has reduced its expected revenues by a factor of 2 (and by a factor of 3 relative to a comprehensive minimum tax of 20%).
  • Third, tax evasion – including grey-zone evasion at the border of legality – is increasingly happening domestically. Global billionaires have effective tax rates equivalent to 0% to 0.5% of their wealth, due to the frequent use of shell companies to avoid income taxation. To date no serious attempt has been made to address this situation, which risks undermining the social acceptability of existing tax systems.

We make six proposals to address the issues identified in this report. A key proposal is to institute a global minimum tax on billionaires, equal to 2% of their wealth. We provide a first estimation of the revenue potential of this measure, showing that it would raise close to $250 billion (from less than 3,000 individuals) annually. A strengthened global minimum tax on multinational companies, free of loopholes, would raise an additional $250 billion per year. To give a sense of the magnitudes involved, recent studies estimate that developing countries need $500 billion annually in additional public revenue to address the challenges of climate change1 – needs that could thus be fully addressed by the two main reforms we propose. All proposals, including potential objections, are thoroughly detailed in Chapter 5.

A key message of this report is that tax evasion is not a law of nature but a policy choice. As interconnected nations we can choose free-for-all policies that allow it to fester, or we can choose coordination to curb it. It is also possible to make major progress through unilateral action, should ambitious global agreements fail.

The Compliance Effects of the Automatic Exchange of Information: Evidence from the Swiss Tax Amnesty

This paper studies how the introduction of multilateral automatic exchange of information (AEOI) in 2017 affects tax compliance. Exploiting rich tax data, variation generated by the interplay of the Swiss tax amnesty with the AEOI, and difference-in-differences designs, I document substantial compliance responses. At the macro level, about 107k taxpayers (2% of all) were pushed to participate in amnesty by the AEOI. Together, they disclosed around 35.2 billion Swiss francs in hidden assets—more than 5% of GDP. I show that the behavioral compliance responses persists at the micro level. Once a tax evader enters the amnesty, their wealth on average increases by 50% and remains at this higher level in subsequent years (relative to the control group). Lastly, I provide evidence that tax evasion is widespread and more evenly distributed in Switzerland than in other European countries—which is consistent with Switzerland’s lack of third-party reporting prior to the AEOI.

Benchmarking Country-by-Country Reports

Country-by-Country Reports (CbCRs) have emerged as a unique public source of information to track the country-by-country activities of multinational corporations. However, concerns about double counting and comparability have raised questions about the reliability of these reports for economic analyses. In this paper, we conduct a benchmark analysis focusing on publicly available CbCRs to assess the reliability of CbCR information compared to respective consolidated financial information. Our findings suggest only limited double counting issues. Most CbCR information matches well with the consolidated information, with only a few exceptions. Nonetheless, we document differences in the definition of variables and in the scope of the reports that may complicate comparisons across multinational corporations. We subsequently discuss the implications of our findings for the use of CbCRs as a source of information in economic analyses. In addition, we provide recommendations for improving the reliability and comparability of CbCR information.

Corporate Tax Avoidance and Sales

This paper investigates the influence of corporate tax avoidance (CTA) on firm-level sales, and its aggregate implications. CTA gives a competitive advantage to avoiding firms, which affects the distribution of sales in the economy. We find a causal impact of CTA on sales in US firm-level data. CTA increased more among the largest firms, which has reinforced their dominant position. A quantitative exercise reveals that the strength of CTA in shaping changes in the distribution of sales varies across industries. In industries like computers or chemicals, CTA can explain up to 10%-30% of the increase in concentration from 1994 to 2017. Further analysis shows the impact.

Tax Avoidance and the Complexity of Multinational Enterprises

Does the complexity of the ownership structure of multinational enterprises’ (MNEs) enable tax avoidance? We characterize as complex an MNE’s ownership structure in which the headquarter owns its subsidiaries through a chain of intermediaries and we build a measure defined as the mean number of layers between affiliates and the headquarter. We use firm-level cross-country data to show that affiliates belonging to more complex MNEs are more likely to report zero profit, which is consistent with complexity enabling tax avoidance by multinationals. Our results underline that only the more complex MNEs shift profits away from their high-tax affiliates, while MNEs with flat ownership structures do not display such pattern.

Effective Tax Rates and Firm Size

This paper provides novel evidence on the relationship between firm size and effective corporate tax rates using full-population administrative tax data from 13 countries. In all countries, small firms face lower effective tax rates than mid-sized firms due to reduced statutory tax rates and a higher propensity to register losses. In most countries, effective tax rates fall for the largest firms due to the take-up of tax incentives. As a result, a third of the top 1 percent of firms face effective tax rates below the global minimum tax of 15 percent. The minimum tax could raise corporate tax revenue by 27 percent in the median sample country.

Does A Progressive Wealth Tax Reduce Top Wealth Inequality? Evidence From Switzerland

Like in many other countries, wealth inequality has increased in Switzerland over the last fifty years. By providing new evidence on cantonal top wealth shares for each of the 26 cantons since 1969, we show that the overall trend masks striking differences across cantons, both in levels and trends. Combining this with variation in cantonal wealth taxes, we then estimate an event study model to identify the dynamic effects of reforms to top wealth tax rates on the subsequent evolution of wealth concentration. Our results imply that a reduction in the top marginal wealth tax rate by 0.1 percentage points increases the top 1% (0.1%) wealth share by 0.9 (1.2) percentage points five years after the reform. This suggests that wealth tax cuts over the last 50 years explain roughly 18% (25%) of the increase in wealth concentration among the top 1% (0.1%).