欧洲央行-全球利润转移的证据以及跨时间的全球证据（英）

Working Paper Series Global evidence on profit shifting within firms and across time Fotis Delis, Manthos D. Delis, Luc Laeven, Steven Ongena Disclaimer: This paper should not be reported as representing the views of the European Central Bank (ECB). The views expressed are those of the authors and do not necessarily reflect those of the ECB. No 3071 Abstract: We provide estimates of profit shifting for over 2 million firm-year observations in100 countries over the period 2009–2020. Employing nonparametric estimation techniqueswithin a mainstay model of profit shifting, we examine how the profits of both parent andsubsidiary firms within a multinational group respond to marginal changes in the composite taxindicator. The key advantage of this approach is that it yields firm-year estimates of profitshifting. Multinational firms engage in extensive profit shifting by maintaining affiliates in low-tax countries and zero-tax havens. Multinational groups with an ultimate tax-haven ownerexhibit the largest profit response to tax incentives. Our new database opens important avenuesfor analyzing the sources and effects of profit shifting.Keywords: Profit shifting; multinational enterprises; nonparametric estimation; tax arbitrage;global sampleJEL Classification: F23; H25; H26; H32; M41ECB Working Paper Series No 30711Executive summary: Large global companies commonly engage in tax planning strategies tomove their profits from high-tax countries to low-tax (or no-tax) countries to reduce the amountof taxes they pay. Such “shifting” of profits across borders within multinational enterprises isknown as “profit shifting”. Such profit-shifting practices cost governments billions of USdollars in lost tax revenues annually. This has triggered policy changes from governments tocontain this practice. The most prominent policy change is the June 2021 agreement among G7finance ministers to seek a minimum global corporate tax rate of at least 15 percent, whichfollowed the OECD’s Base Erosion and Profit Shifting (BEPS) initiative to limit profit shifting.In this paper, we provide global estimates of profit shifting using firm level data. Most existingstudies either focus only on profit shifting within or across firms, and do not consider variationin profit shifting over time. We use the most complete sample of firms and their foreignsubsidiaries to date to estimate profit shifting both within and across firms and measure shiftsin such patters over time. In total, our dataset covers more than 2 million firm-year observationsof around half a million firms from across 100 different countries over the period 2009–2020.Our new estimates of profit shifting enable us to trace the origin of profit shifting and to betteridentify the underlying drivers of profit shifting. Moreover, our time-varying estimates of profitshifting, along with dynamic information on the corporate ownership links, allow us to identifythe physical routes of p