Assessing Profit Shifting Using Country-by-Country Reports: A Nonlinear Response to Tax Rate Differentials

Barbara Bratta, Vera Santomartino and Paolo Acciari

National Tax Journal, 2024, vol. 77, issue 2, 349 - 380

Abstract: We analyze profit shifting carried out by multinational enterprises (MNEs) worldwide and estimate associated tax-revenue losses using firm-level data from mandatory country-by-country reporting. We show how the data set outperforms existing data sets, expand the analysis of the nonlinear response of profits to tax rates, and investigate nonlinear responses by MNE nationality and size. Our results suggest that the elasticity of profits with respect to corporate tax rates is eight times larger than the literature in lowest-tax jurisdictions and 60 percent lower among jurisdiction pairs with smaller tax rate differences. Results suggest fixed costs in profit shifting exist and differ by MNE headquarters.

Date: 2024
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Working Paper: Assessing profit shifting using Country-by-Country Reports: a non-linear response to tax rate differentials (2021)
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