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Taxation of rms and development
Jukka Pirttilä (University of Tampere and UNU-WIDER)
Finnfund 1 September 2017
1 / 22
Outline
Introduction
The importance of foreign rms
Estimates of international tax evasion
Conclusion
2 / 22
Motivation
Tax capacity in developing countries improving, but the tax
take still too low
Developing countries are relatively more dependent on
corporate income tax (CIT) revenues
These countries need jobs and investments, and foreign direct
investment (FDI) and multinational enterprises (MNE)s can
help in reaching this goal
How does one strike a good balance in attracting investment
and generating sucient revenues?
Especially: How severe are the losses from international tax
avoidance by MNEs?
3 / 22
An aside: tax incidence
Tax incidence: the entity that remits the tax is not necessarily
the same as the one who bears the economic burden of it
In the case of CIT, the incidence can fall on
owners (in terms of lower after-tax prot)
workers (lower demand for labour, lower wage rates)
consumers (higher prices, as in the case of the VAT)
In economics literature, ample evidence that workers pay a
large burden of the CIT
Theoretically this eect is especially pronounced for the case
of MNEs
Their after-tax prot determined at the international capital
market. If taxes increase, pre-tax prots must increase
4 / 22
Outline
Introduction
The importance of foreign rms
Estimates of international tax evasion
Conclusion
5 / 22
Outline
Introduction
The importance of foreign rms
Estimates of international tax evasion
Conclusion
6 / 22
Background
FDI a much more signicant source of nance to developing
countries than aid
A recent survey paper (meta study) by Demena and van
Bergeijk (2017):
review 70 empirical studies for 30 developing countries
nd that FDI has a positive and statistically signicant impact
on the productivity of domestic rms
This is important
FDI not only aects the target rm, but generate positive
externalities (spillovers)
FDI is more than domestic investment (knowledge transfer)
7 / 22
Tax take
10203040
Totaltaxrevenuesincl.SSC
1980 1990 2000 2010 2020
Calendar year (nearest)
Low Income Lower-Middle Income
Upper-Middle Income High Income
Figure: Tax to GDP ratios by income groups. Source: Own calculations
based on the ICTD UNU-WIDER GRD data.
8 / 22
The relative role of CIT
.05.1.15.2
CITrevenues,shareofallrevenues
1980 1990 2000 2010 2020
Calendar year (nearest)
Low Income Lower-Middle Income
Upper-Middle Income High Income
Figure: CIT revenues as a share of overall tax revenue. Source: Own
calculations based on the ICTD UNU-WIDER GRD data.
9 / 22
The relative role of FDI
10 / 22
Outline
Introduction
The importance of foreign rms
Estimates of international tax evasion
Conclusion
11 / 22
Some well-known estimates
Estimates by Global Financial Integrity (2015) have attracted
much attention
Their method
hot-money-narrow + trade misinvoicing = total illicit ows
200 billion USD + 800 billion USD = 1 trillion USD
The former is based on errors and omissions in the balance of
payments
It is the trade misinvoicing part that is responsible for the
great majority of ows
whether this part is right is decisive
12 / 22
Trade misinvoicing channel
If rich country imports exceed exports from developing country
+ trade costs (10%) = seen as evidence of export
underinvoicing = illicit outow
Similarly overinvoiced imports lead to unreported outows
Some problems
estimates can be sensitive to what is assumed of trade costs
all false claims are assumed to be made by developing countries
estimates very fragile (uctuate a lot from year to year)
products dierently categorized in origin and destination
countries (that is why product-level analysis often misleading)
13 / 22
Trade misinvoicing channel II
Perhaps most puzzling is that if one estimates also illicit
inows using the same method (but a mirror image), they
exceed illicit outows. So on average, developing countries
benet from these ows
Bottom line: it is hard to use their numbers to come up with
convincing estimates (see also Nitsch 2016)
Even if numbers were correct, one needs to remember that the
greatest outows are from large middle-income countries,
meaning that public nance issues in poorest countries would
not be solved if these ows were curtailed
14 / 22
Estimates of hidden wealth by individuals
Zucman (2013, 2015) estimates the extent of nancial wealth
held by private individuals oshore
The method relies on discrepancies in assets and liabilities
positions of countries
worldwide total liabilities exceed total assets as not all assets
are reported
there is also a systematic pattern that tax havens feature the
largest discrepancies
He estimates that 8% of nancial wealth is hidden in tax
havens
Using assumptions on rates of return and eective capital
income tax rates, the stock can be changed into a ow of
revenue losses, summing up to around 200 billion USD
annually
15 / 22
Indirect estimates of income shifting by MNEs
While not necessarily illicit, income shifting by deliberate
manipulation of transfer pricing by multinational companies is
also quite obviously problematic
A recent UNU-WIDER study (Johannesen, Tørsløv, and Wier,
2016) utilizing rm-level data indicates that the problem is a
more severe one for countries outside of EU
Estimates by the OECD (2015) and the IMF (Crivelli,
de Mooij, and Keen, 2016) suggest that revenue losses would
be in the range of 100-240 billion globally or 200 billion from
the non-OECD countries
Further disaggregated analysis by Cobham and Janský (2017)
reveals that the revenue loss for Africa slightly larger relative
to GDP than for other non-OECD countries
16 / 22
Direct estimates using product-level data
Within UNU-WIDER project, one has access to product
category level data within rms for South Africa
Can compare imports of same goods by the same rm with
internal and external partners
If the trade is within the same rm, the group has an incentive
to charge a higher price for imports coming from low-tax
countries
Conrms that this is the case: internal imports from low-tax
countries is overpriced by 10%
signicant, but not larger than evidence from similar studies
from developed countries suggests
17 / 22
What do the (aggregate) numbers mean for Africa?
Zucman (2015) calculates that Africa loses tax revenues
amounting to 14 billion USD due to capital held oshore by
individuals
Applying the estimates of Crivelli, de Mooij, and Keen (2016)
implies that the revenue loss from income-shifting by MNEs is
approximately 20 billion USD
At the same time, ODA to Africa (50 billion USD) exceeds the
revenue loss due to illegal capital ight in Africa
the revenue loss is around 10% of their tax revenues
To sum up: illicit capital ight is a serious problem but
unlikely to solve African revenue issues. Domestic sources
must continue to be responsible for the bulk of tax collection
18 / 22
Outline
Introduction
The importance of foreign rms
Estimates of international tax evasion
Conclusion
19 / 22
Final thoughts
Poor countries need FDI
They are dependent on the CIT revenue, and lose part of it
due to illegal transfer pricing
Combating tax avoidance is important but alone not sucient
to solve the revenue problems of developing countries
Tax havens facilitate evasion and crime (due to secrecy).
Unclear if they serve any useful role
Many argue that special economic zones do not work very well
in Africa. Unclear if tax concessions oered to international
companies have been useful
Technical assistance that is targeted to improve the tax
capacity of revenue authorities holds a great promise. No
evidence about its impacts
20 / 22
References I
Cobham, A., and P. Janský (2017): Global distribution of revenue loss
from tax avoidance, Working Paper 55, UNU-WIDER.
Crivelli, E., R. de Mooij, and M. Keen (2016): Base Erosion, Prot
Shifting and Developing Countries, FinanzArchiv: Public Finance
Analysis, 72(3), 268301.
Demena, B. A., and P. A. G. van Bergeijk (2017): A META-ANALYSIS
OF FDI AND PRODUCTIVITY SPILLOVERS IN DEVELOPING
COUNTRIES, Journal of Economic Surveys, 31(2), 546571.
Global Financial Integrity (2015): Illicit Financial Flows from Developing
Countries: 2004-2013, .
Johannesen, N., T. Tørsløv, and L. Wier (2016): Are Less Developed
Countries more Exposed to Multinational Tax Avoidance?: Method
and Evidence from Micro-Data, Working Paper 10, UNU-WIDER.
Nitsch, V. (2016): Trillion Dollar estimate: Illicit nancial ows from
developing countries, Discussion Papers in Economics 227,
Technische Universität Darmstadt.
21 / 22
References II
OECD (2015): Measuring and Monitoring BEPS, Action 112015 Final
Report, Base Erosion and Prot Shifting Project.
Zucman, G. (2013): The Missing Wealth of Nations, Are Europe and
the U.S. net Debtors or net Creditors?, Quarterly Journal of
Economics, 128(3), 13211364.
(2015): The Hidden Wealth of Nations. The Scourge of Tax
Havens. The University of Chicago Press.
22 / 22

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Taxation of firms and development

  • 1. Taxation of rms and development Jukka Pirttilä (University of Tampere and UNU-WIDER) Finnfund 1 September 2017 1 / 22
  • 2. Outline Introduction The importance of foreign rms Estimates of international tax evasion Conclusion 2 / 22
  • 3. Motivation Tax capacity in developing countries improving, but the tax take still too low Developing countries are relatively more dependent on corporate income tax (CIT) revenues These countries need jobs and investments, and foreign direct investment (FDI) and multinational enterprises (MNE)s can help in reaching this goal How does one strike a good balance in attracting investment and generating sucient revenues? Especially: How severe are the losses from international tax avoidance by MNEs? 3 / 22
  • 4. An aside: tax incidence Tax incidence: the entity that remits the tax is not necessarily the same as the one who bears the economic burden of it In the case of CIT, the incidence can fall on owners (in terms of lower after-tax prot) workers (lower demand for labour, lower wage rates) consumers (higher prices, as in the case of the VAT) In economics literature, ample evidence that workers pay a large burden of the CIT Theoretically this eect is especially pronounced for the case of MNEs Their after-tax prot determined at the international capital market. If taxes increase, pre-tax prots must increase 4 / 22
  • 5. Outline Introduction The importance of foreign rms Estimates of international tax evasion Conclusion 5 / 22
  • 6. Outline Introduction The importance of foreign rms Estimates of international tax evasion Conclusion 6 / 22
  • 7. Background FDI a much more signicant source of nance to developing countries than aid A recent survey paper (meta study) by Demena and van Bergeijk (2017): review 70 empirical studies for 30 developing countries nd that FDI has a positive and statistically signicant impact on the productivity of domestic rms This is important FDI not only aects the target rm, but generate positive externalities (spillovers) FDI is more than domestic investment (knowledge transfer) 7 / 22
  • 8. Tax take 10203040 Totaltaxrevenuesincl.SSC 1980 1990 2000 2010 2020 Calendar year (nearest) Low Income Lower-Middle Income Upper-Middle Income High Income Figure: Tax to GDP ratios by income groups. Source: Own calculations based on the ICTD UNU-WIDER GRD data. 8 / 22
  • 9. The relative role of CIT .05.1.15.2 CITrevenues,shareofallrevenues 1980 1990 2000 2010 2020 Calendar year (nearest) Low Income Lower-Middle Income Upper-Middle Income High Income Figure: CIT revenues as a share of overall tax revenue. Source: Own calculations based on the ICTD UNU-WIDER GRD data. 9 / 22
  • 10. The relative role of FDI 10 / 22
  • 11. Outline Introduction The importance of foreign rms Estimates of international tax evasion Conclusion 11 / 22
  • 12. Some well-known estimates Estimates by Global Financial Integrity (2015) have attracted much attention Their method hot-money-narrow + trade misinvoicing = total illicit ows 200 billion USD + 800 billion USD = 1 trillion USD The former is based on errors and omissions in the balance of payments It is the trade misinvoicing part that is responsible for the great majority of ows whether this part is right is decisive 12 / 22
  • 13. Trade misinvoicing channel If rich country imports exceed exports from developing country + trade costs (10%) = seen as evidence of export underinvoicing = illicit outow Similarly overinvoiced imports lead to unreported outows Some problems estimates can be sensitive to what is assumed of trade costs all false claims are assumed to be made by developing countries estimates very fragile (uctuate a lot from year to year) products dierently categorized in origin and destination countries (that is why product-level analysis often misleading) 13 / 22
  • 14. Trade misinvoicing channel II Perhaps most puzzling is that if one estimates also illicit inows using the same method (but a mirror image), they exceed illicit outows. So on average, developing countries benet from these ows Bottom line: it is hard to use their numbers to come up with convincing estimates (see also Nitsch 2016) Even if numbers were correct, one needs to remember that the greatest outows are from large middle-income countries, meaning that public nance issues in poorest countries would not be solved if these ows were curtailed 14 / 22
  • 15. Estimates of hidden wealth by individuals Zucman (2013, 2015) estimates the extent of nancial wealth held by private individuals oshore The method relies on discrepancies in assets and liabilities positions of countries worldwide total liabilities exceed total assets as not all assets are reported there is also a systematic pattern that tax havens feature the largest discrepancies He estimates that 8% of nancial wealth is hidden in tax havens Using assumptions on rates of return and eective capital income tax rates, the stock can be changed into a ow of revenue losses, summing up to around 200 billion USD annually 15 / 22
  • 16. Indirect estimates of income shifting by MNEs While not necessarily illicit, income shifting by deliberate manipulation of transfer pricing by multinational companies is also quite obviously problematic A recent UNU-WIDER study (Johannesen, Tørsløv, and Wier, 2016) utilizing rm-level data indicates that the problem is a more severe one for countries outside of EU Estimates by the OECD (2015) and the IMF (Crivelli, de Mooij, and Keen, 2016) suggest that revenue losses would be in the range of 100-240 billion globally or 200 billion from the non-OECD countries Further disaggregated analysis by Cobham and Janský (2017) reveals that the revenue loss for Africa slightly larger relative to GDP than for other non-OECD countries 16 / 22
  • 17. Direct estimates using product-level data Within UNU-WIDER project, one has access to product category level data within rms for South Africa Can compare imports of same goods by the same rm with internal and external partners If the trade is within the same rm, the group has an incentive to charge a higher price for imports coming from low-tax countries Conrms that this is the case: internal imports from low-tax countries is overpriced by 10% signicant, but not larger than evidence from similar studies from developed countries suggests 17 / 22
  • 18. What do the (aggregate) numbers mean for Africa? Zucman (2015) calculates that Africa loses tax revenues amounting to 14 billion USD due to capital held oshore by individuals Applying the estimates of Crivelli, de Mooij, and Keen (2016) implies that the revenue loss from income-shifting by MNEs is approximately 20 billion USD At the same time, ODA to Africa (50 billion USD) exceeds the revenue loss due to illegal capital ight in Africa the revenue loss is around 10% of their tax revenues To sum up: illicit capital ight is a serious problem but unlikely to solve African revenue issues. Domestic sources must continue to be responsible for the bulk of tax collection 18 / 22
  • 19. Outline Introduction The importance of foreign rms Estimates of international tax evasion Conclusion 19 / 22
  • 20. Final thoughts Poor countries need FDI They are dependent on the CIT revenue, and lose part of it due to illegal transfer pricing Combating tax avoidance is important but alone not sucient to solve the revenue problems of developing countries Tax havens facilitate evasion and crime (due to secrecy). Unclear if they serve any useful role Many argue that special economic zones do not work very well in Africa. Unclear if tax concessions oered to international companies have been useful Technical assistance that is targeted to improve the tax capacity of revenue authorities holds a great promise. No evidence about its impacts 20 / 22
  • 21. References I Cobham, A., and P. Janský (2017): Global distribution of revenue loss from tax avoidance, Working Paper 55, UNU-WIDER. Crivelli, E., R. de Mooij, and M. Keen (2016): Base Erosion, Prot Shifting and Developing Countries, FinanzArchiv: Public Finance Analysis, 72(3), 268301. Demena, B. A., and P. A. G. van Bergeijk (2017): A META-ANALYSIS OF FDI AND PRODUCTIVITY SPILLOVERS IN DEVELOPING COUNTRIES, Journal of Economic Surveys, 31(2), 546571. Global Financial Integrity (2015): Illicit Financial Flows from Developing Countries: 2004-2013, . Johannesen, N., T. Tørsløv, and L. Wier (2016): Are Less Developed Countries more Exposed to Multinational Tax Avoidance?: Method and Evidence from Micro-Data, Working Paper 10, UNU-WIDER. Nitsch, V. (2016): Trillion Dollar estimate: Illicit nancial ows from developing countries, Discussion Papers in Economics 227, Technische Universität Darmstadt. 21 / 22
  • 22. References II OECD (2015): Measuring and Monitoring BEPS, Action 112015 Final Report, Base Erosion and Prot Shifting Project. Zucman, G. (2013): The Missing Wealth of Nations, Are Europe and the U.S. net Debtors or net Creditors?, Quarterly Journal of Economics, 128(3), 13211364. (2015): The Hidden Wealth of Nations. The Scourge of Tax Havens. The University of Chicago Press. 22 / 22