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Business and Economics > Corporate Taxation

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Cover IMF Working Papers
Base Erosion, Profit Shifting and Developing Countries
Ernesto Crivelli
,
Ruud A. de Mooij
, and
Mr. Michael Keen
International corporate tax issues are prominent in public debate, notably with the G20-OECD project addressing Base Erosion and Profit Shifting (‘BEPS’). But while there is considerable empirical evidence for advanced countries on the cross-country fiscal externalities at the heart of these issues, there is almost none for developing countries. This paper uses panel data for 173 countries over 33 years to explore their magnitude and nature, focusing particularly on developing countries and applying a new method to distinguish between spillover effects through real decisions and through avoidance —and quantify the revenue impact of the latter. The results suggest that spillover effects on the tax base are if anything a greater concern for developing countries than for advanced—and a significant one.
Keywords:
WP; Corporate income tax; BEPS; tax avoidance; international taxation; spillover effect; tax haven; simple average; CIT base; rate spillover; profit shifting; competition literature; spillover equation; Average effective tax rate; Spillovers; Caribbean; Sub-Saharan Africa
Cover Policy Papers
Spillovers in International Corporate Taxation
International Monetary Fund
This paper explores the nature, significance and policy implications of spillovers in international corporate taxation—the effects of one country’s rules and practices on others. It complements current initiatives focused on tax avoidance by multinationals, notably the G20-OECD project on Base Erosion and Profit shifting (BEPS). The paper draws on the IMF’s experience on international tax issues with its wide membership, including through technical assistance (TA), and on its previous analytical work, to analyze spillovers and how they might be addressed. In doing so, it goes beyond current initiatives to look at a wide set of possible responses.
Keywords:
PP; double taxation; residence country; tax system; single tax; taxable income; transfer pricing; withholding tax; income tax; cost of capital; companies resident; capital gain; Intra-company debt shifting; Corporate income tax; Corporate taxes; Spillovers; Personal income; Transfer pricing; Global