Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/314680 
Year of Publication: 
2025
Series/Report no.: 
CESifo Working Paper No. 11641
Publisher: 
CESifo GmbH, Munich
Abstract: 
Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh, Egypt, Indonesia, Kenya, Uganda and Zambia, are vulnerable to substantial potential losses of withholding tax revenue by treaty shopping. The analysis combines tax parameters of more than a hundred countries with an algorithm from network theory, which simulates the tax minimizing behaviour of multinational enterprises. We introduce the notion of potentially aggressive tax treaties. These are the key treaties in treaty shopping routes, that may lead to substantial tax revenue losses in developing countries. Moreover, the treaty partners are often in a prime position to top-up tax undertaxed profits of developing countries that offer tax incentives to attract investment, thus nullifying the incentive effects.
Subjects: 
tax treaties
treaty shopping
developing countries
network analysis
withholding taxes
aggressive tax treaties
global minimum tax
JEL: 
F23
H25
H26
O10
Document Type: 
Working Paper
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