法国预测与国际信息中心-利润转移的工具（英）

Highlights Using firm-level data, we provide the first joint quantification of the three main profit-shifting channels: transfer mispricing in goods trade, intangible assets and services traded with tax havens, and intra-firm debt. Transfer mispricing in goods trade is the dominant channel in France, accounting for €10 billion (0.4% of French GDP) in shifted profits, followed by services (up to €6 billion) and debt (€2 billion). Although significant, direct estimates of profit shifting explain only half of France's total missing profits estimated from indirect evidence. We identify cross-border digital payments and understudied debt instruments as key blind spots likely contributing to the remaining missing profits.The Instruments of Profit ShiftingNo 2025-16 – November 2025 Working PaperKevin Parra Ramirez & Vincent Vicard CEPII Working Paper The Instruments of Profit Shifting Abstract While multinational enterprises (MNEs) shift hundreds of billions in profits to low-tax jurisdictions annually, how they do remains disputed. Using firm-level data for France in 2018, we provide the first joint quantification of the three main profit-shifting channels: transfer mispricing in goods trade, intangible assets and services traded with tax havens, and intra-firm debt. We find empirical evidence for all three instruments, but transfer mispricing dominates quantitatively (€10 billion, 0.4\% of GDP), followed by services (up to €6 billion) and debt (€2 billion). Although significant, these direct estimates account for half of total missing profits in France, as estimated indirectly from the location of MNE profits. We document two key blind spots likely to close this gap: cross-border digital payments by households and understudied debt instruments (e.g., securities). KeywordsTax Avoidance, Multinational Firms, Profit Shifting, FDI, Trade. JELH26, H25, H32, F14, F23.Working Paper© CEPII, PARIS, 2025Centre d’études prospectives et d’informations internationales 20, avenue de Ségur TSA 10726 75334 Paris Cedex 07contact@cepii.fr www.cepii.fr – @CEPII_Paris Press contact: presse@cepii.frCEPII Working PaperContributing to research in international economicsCEPII (Centre d’Études Prospectives et d’Informations Internationales) is a French institute dedicated to producing independent, policy-oriented economic research helpful to understand the international economic environment and challenges in the areas of trade policy, competitiveness, macroeconomics, international finance and growth.EdItoRIAl dIRECtoR: AntoInE BouëtVISuAl dESIgn And PRoduCtIon: lAuRE BoIVInISSN 2970-491XNovember 2025To subscribe to The CEPII Newsletter: www.cepii.fr/KeepInformedAll rights reserved. Opinions expressed in this publication are those of the author(s) alone.CEPII Working PaperThe instruments of prot shiftingThe instruments of prot shifting 1Kevin Parra Ramirez* and Vincent Vicard„1.IntroductionMultinational enterprises (MNEs) shift hundreds of billions in prots to low-tax ju