Double Counting Accounting: How Much Profit of Multinational Enterprises Is Really in Tax Havens?

Abstract

Putting an end to the base erosion and profit shifting (BEPS) activity of multinational enterprises (MNEs) is high on national agendas. Influential work in academic and policy circles suggests that the magnitude of BEPS problem is large. We show that these magnitudes are overstated due to researchers’ misunderstanding of the accounting treatment of indirectly-owned foreign affiliates in the U.S. international economic accounts data. Our work has far-reaching implications as all country-level MNE data must apply some accounting convention that can make international comparisons difficult. We explain how this accounting treatment leads to double counting of foreign income and to its misattribution to incorrect jurisdictions. We demonstrate a simple correction, and show that the correction significantly reduces the magnitude of the BEPS estimates. For instance, our correction reduces an estimate of the U.S. fiscal effects of BEPS from 30-45% to 4-8% of corporate tax revenues lost to BEPS activity of MNEs (Clausing 2016).

Keywords: base erosion and profit shifting, measurement, accounting, foreign direct investment

JEL Classification: H32, M41, O50