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Research notes · Finance

Why do careful estimates of profit shifting differ by an order of magnitude?

Profit Shifting in a Globalized World

Dhammika Dharmapala (2019) · AEA Papers and Proceedings 109

Article ↗ · Replication data ↗ (openICPSR)

The archive requires an account we do not hold, so the files were not opened. What follows rests on the published abstract and on this platform's own observations.

What the authors found

Dharmapala reviews the measurement of profit shifting and finds the divergence between microeconomic estimates from firm data and macroeconomic estimates from national accounts is not a matter of better or worse technique. The two approaches draw the boundary between tax avoidance and ordinary behavioural response to taxes in different places, so they are measuring different things. He also documents that OECD countries substantially strengthened anti-avoidance rules between 2000 and 2014.

What our data adds

This database sits firmly on the macro side of the divide Dharmapala describes, and the note on the royalty ledger shows what that view looks like: Luxembourg paying 13.21 per cent of GDP for the use of intellectual property, Cyprus receiving 8.12 per cent. Those figures are dramatic and, by this paper's argument, systematically ambiguous — they include real licensing alongside transfer pricing, and no macro series can separate them. The microdata studies that can produce much smaller numbers for the same phenomenon.

FigureValueIndicator
Luxembourg, IP payments as a share of GDP 13.21% BM.GSR.ROYL.CD
Cyprus, IP receipts 8.12% BX.GSR.ROYL.CD

Every figure here is computed from observations in this database and can be charted, downloaded or queried.

What this cannot show

The most useful thing this note can do is warn against a figure derived from our own data. It would be easy to total the royalty flows through low-tax jurisdictions and present the result as the scale of profit shifting. That number would be a macro estimate with all the boundary problems Dharmapala identifies, and quoting it without them would be exactly the error the paper is about.

The data behind it

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