Tax Transparency by Multinationals: Trends in Country-by-Country Reports Public Disclosure

Country-by-Country Reporting is a key data source for understanding the activities of multinational firms. This note explores public Country-by-Country Reports (CbCRs) published by multinational companies to highlight several important trends. First, while only a small number of large multinationals currently publish their CbCRs, the number of companies is increasing rapidly for both large and smaller multinational firms. However, these reports are scattered across different sets of documents, making collecting and analysing them challenging. Second, CbCR publishing is driven by European companies, especially companies active in the extractive sector. Finally, published reports are generally not complete in terms of variables included but present a satisfactory geographical disaggregation in most cases.

Fiscal Consequences of Corporate Tax Avoidance

We study the consequences of multinational tax avoidance on the structure of government tax revenues. To motivate our analysis, we show that countries with high revenue losses due to pro t shifting have lower corporate tax revenues and rates and higher indirect tax revenues and rates. To establish causality, we use German municipal data and analyse how changes in municipal trade tax rates levied on corporate profits affect local tax revenue structure. Following a trade tax rate increase, we find that municipalities with high exposure to aggressive multinationals experience a significant decline in trade tax revenue levels and shares.

Behavioral Responses to Special Tax Regimes for the Super – Rich: Insights from Swiss Rich Lists

We collect, digitize, and supplement Swiss rich lists published in the “BILANZ” business magazine since 1989, to gain new insights on the structure and dynamics of top wealth in Switzerland. We show that 60% of the super-rich are heirs—a fraction twice as large as in the US, where many super-rich are self-made—and that half of the super-rich residing in Switzerland are foreign-born. Based on this new dataset, we estimate the sensitivity of the location choice of super-rich foreigners to a preferential tax scheme, under which wealthy foreigners are taxed on their expenses, rather than their true income and wealth. We are the first to evaluate this infamous policy (which bears similarities with “non-dom” taxation in the UK or Italy), and show that when some Swiss cantons abolished this practice, their stock of super-rich foreigners dropped by 30% as a consequence. We find no response for the unaffected Swiss super-rich.

The Long Way to Tax Transparency

In this paper, we analyse a sample of voluntarily published country-by-country reports (CbCRs) of 35 multinational enterprises (MNEs). We assess the value added and the limitations of qualitative and quantitative information provided in the reports based on a comparison to individual MNEs’ annual financial reports and aggregate CbCR data provided by the OECD. In terms of data quality, we find that the inclusion of intra company dividends and equity-accounted profits are a minor concern on average but that for individual MNEs corrections might be substantial. Our sample MNEs seem to pay higher effective tax rates than the global average and many of them report relatively little profit in tax havens. We only find a very weak correlation of the location of profits and effective tax rates. This might indicate that more tax transparent MNEs avoid taxes less aggressively. However, our assessment of different tax risk indicators reveals important variations between companies. 

Increasing Cross-Border Ownership of Real Estate: Evidence from Norway

This paper is the first to estimate the full extent of foreign-owned commercial and residential real estate in a country, including both direct and indirect ownership. We utilise unique Norwegian administrative data with reliable market value estimates and country-level ownership information. Overall, 2 percent of Norwegian real estate assets were foreign-owned in 2017, while this share amounts to 10 percent for assets owned by Norwegian corporations. Foreign ownership has increased over the last decade, and ownership from tax havens even more rapidly. Ownership from neighbouring countries and Luxembourg is especially large.

Global Profit Shifting, 1975 – 2019

This paper constructs time series of global profit shifting covering the 2015–19 period, during which major international efforts were implemented to curb profit shifting. We find that (i) multinational profits grew faster than global profits, (ii) the share of multinational profits booked in tax havens remained constant at around 37 per cent, and (iii) the fraction of global corporate tax revenue lost due to profit shifting rose from 9 to 10 per cent. We extend our time series back to 1975 and document a remarkable increase of multinational profits and global profit shifting from 1975 to 2019.

A Modern Excess Profit Tax

This note presents a new way to tax excess profits. We propose to tax the rise in the stock market capitalization of companies that benefit from extraordinary circumstances, such as energy firms following the invasion of Ukraine in February 2022. Targeting the rise in stock market capitalization (which is easily observable) makes the tax much harder to avoid than standard excess profit taxes, and allows to capture rents irrespective of where multinational companies book their profits. We apply this proposal to energy companies that are headquartered or have sales in the European Union. We estimate that taxing the January 2022 to September 2022 valuation gains of energy firms at a rate of 33% would generate around €65 billion in revenue (0.3% of GDP) for the European Union. We discuss implementation practicalities and compare our proposals to other plans made to tax excess profits.

Revealing 21% of GDP in Hidden Assets: Evidence from Argentina’s Tax Amnesty

The paper studies the effectiveness of tax amnesties and their impacts on capital taxation and public spending. We leverage rich policy variation from Argentina, which implemented the world’s most successful program, reportedly revealing assets worth 21% of GDP. First, despite substantial offshore tax evasion, declared foreign assets quadrupled. Second, tax progressivity improved because disclosures were extensive among the wealthiest 0.1%. Third, improving tax compliance has sizable fiscal externalities on capital taxes and social transfers: the wealth and capital income tax bases more than doubled, and the earmarked revenue boosted pension benefits by 15%. We end by discussing the lessons from Argentina.

A Modern Excess Profit Tax

This paper presents a new way to tax excess profits. We propose to tax the rise in the stock market capitalization of companies that benefit from extraordinary circumstances, such as energy firms following the invasion of Ukraine in February 2022. Targeting the rise in stock market capitalization (which is easily observable) makes the tax much harder to avoid than standard excess profit taxes, and allows to capture rents irrespective of where multinational companies book their profits. We apply this proposal to energy companies that are headquartered or have sales in the European Union. We estimate that taxing the January 2022 to September 2022 valuation gains of energy firms at a rate of 33% would generate around €80 billion in revenue (0.4% of GDP) for the European Union. We discuss implementation practicalities and compare our proposals to other plans made to tax excess profits.

Will We Ever Be Able to Track Offshore Wealth? Evidence from the Offshore Real Estate Market in the UK

This paper provides evidence of the growing importance of real estate assets in offshore portfolios. We study the implementation of the first multilateral automatic exchange of information norm, the Common Reporting Standard (CRS), which introduces cross-border reporting requirements for financial assets but not for real estate assets. Exploiting administrative data on property purchases made by foreign companies in the UK, we show that the implementation of the CRS led to a significant increase of real estate investments from companies incorporated in the tax havens that were the most exposed to the policy. We confirm that this increase comes from company owners of countries committing to the new standard by identifying the residence country of a sub-sample of buyers using the Panama Papers and other leaked datasets. We estimate that between £16 and £19 billion have been invested in the UK real estate market between 2013 and 2016 in reaction to the CRS, suggesting that at the global scale between 24% and 27% of the money that fled tax havens following this policy were ultimately invested in properties.