Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/279344 
Year of Publication: 
2023
Series/Report no.: 
CESifo Working Paper No. 10593
Publisher: 
Center for Economic Studies and ifo Institute (CESifo), Munich
Abstract: 
We exploit exogenous variation in tax notches created by controlled foreign corporation (CFC) rules to better understand the profit-shifting behavior of multinational enterprises (MNEs) and its consequences for real activity. Using new data on CFC rules and information on direct parent-affiliate ownership links, our identification approach allows us to estimate an unbiased profit-shifting semi-elasticity of about 0.22. Removing incentives to shift profits to particular low-tax locations leads to profit relocation to 'next-best' low-tax countries, allowing firms to circumvent domestic taxation. We do not find any significant effects on parent shareholders, neither in terms of repatriated profit nor in terms of their real economic activity. Other entities within the MNE, where profits get relocated to, see a significant increase in various measures of real activity.
Subjects: 
corporate taxation
profit shifting anti-tax-avoidance rules
multinational enterprise
firm organization
JEL: 
F23
H25
Document Type: 
Working Paper
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