Abusive Tax Avoidance and Globalization Final Paper IPE

When our legitimate revenues are attacked, the whole structure of our Government is attacked. ‘Clever little schemes’ are not admirable when they undermine the foundations of society.

Franklin D Roosevelt

  1. Introduction

Does globalization make it easier for transnational corporations to engage in tax avoidance? The simple answer is yes. Recently, globalization and technological innovations have greatly increased the ability of Multinational Corporations (MNCs) to engage in aggressive tax avoidance. To do this, a widespread number of tactics have been created to take advantage of this new level of interconnectedness and technological advancement (Russell and Brock 2015, 281).

Globalization and its consequences are one of the most debated topics in social sciences today. Some critics state that globalization has led to economic inequality, is keeping the global south underdeveloped, is detrimental to the environment, and transfers too much power from nation states to multinational corporations (MNCs). On the other hand, proponents of globalization point out the absolute reduction of world poverty in the last 30 years and the reduction of inequality across societies (both north and south) as some of the main positive consequences of globalization (Oatley 2012, 347-351). Moreover, they highlight that there is no substantial proof that globalization causes more damage to the environment than imposing overall global trade restrictions. However, there is little debate across the political and economic spectrum about the fact that globalization has led to increasingly strong multinational corporations, which can then engage in practices that are detrimental to governments and to the welfare of their people in general (Oatley 2012, 347-351).

One of the most damaging practices undertaken by MNCs is abusive tax avoidance. It is a practice that is considered “legal” (unlike tax evasion), but which is an artificial stretch of national tax laws. By analyzing what abusive tax avoidance is, how MNCs use Globalization to engage in it, how they increase their profit with such a practice, and its ultimate consequences, it will be possible to highlight the policy implications of such findings and actions that can be undertaken to reduce such practices.

 

  1. Empirical Facts and Literature Review

Tax revenue is one of the most important jobs of any government, comparable to the blood that runs through one’s body. Without it, a state cannot survive. Governments need tax revenue to fulfill their basic tasks for its citizens such as creating and maintaining basic infrastructure, keeping the security apparatus, and caring for the general welfare of hospitals, schools, fire brigades, and the like. Therefore, when corporations avoid paying their fair share of taxes, all these government tasks are put in jeopardy, something which can ultimately lead to social chaos and conflict (Brock and Russel 2015, 278-279). Moreover, since the global financial crisis of 2008, countries have been engaging in austerity measures to balance their budgets. This process usually hurts the poor the most, accelerating a trend of growth in social inequality that has been increasing since the 1980s. This tendency has been exacerbated by aggressive corporate tax avoidance since one of the main results of the political economy of taxation is the redistribution of resources inside a society to mitigate the negative aspects of inequality (Bethencourt and Kunze 2015, 268). This has shift the debate on tax avoidance from a legal perspective to an ethical and moral one, thus reducing the focus in the legality, which nevertheless, is still being debated.

Before getting into the details, it is important to clarify some of the terminology used in this paper. The terms tax mitigation, avoidance, and evasion all have different levels of legality and morality. According to Brown Karen B. (2012, 1), “…Tax avoidance involves arrangement of a transaction in order to obtain a tax advantage, benefit, or reduction in a manner unintended by the tax law. …Mitigation involves use of the tax law to achieve anticipated tax advantages embedded in tax provisions. …Evasion involves outright fraud, concealment, or misrepresentation in order to defeat application of the tax laws…”.

Almost all papers analyzed for the sake of this essay had the same view on the legality of tax avoidance, such as Blaufus et al. (2016) who focused on the possibility of changing the definition of aggressive tax avoidance from legal to illegal and discussed how this measure would reduce its use by MNCs. Jansky and Pratts’s (2015) work gives attention to the use by MNCs operating in India making use of tax havens elsewhere to minimize their corporate taxes and how legal this practice is perceived. However, a more profound analysis is done by de Colle and Bennett (2014). Their paper disagrees with the definitions given by Brown above that tax avoidance is against the “spirit of the law.” Instead, their paper is more specific and classifies tax avoidance into three distinct categories:

  • State-Induced Avoidance: where the corporations or citizens engage in tax avoidance by adhering to tax breaks explicitly put in place by governments in order to achieve certain social goals
  • Strategic Avoidance: practices that lessen the amount of tax paid by corporations but is seen just as a “smart” business practice
  • Toxic Avoidance: practices undertaken to reduce tax liabilities which involve lack of transparency, are contrary to the “spirit” of the law, and create artificial structures or transactions without an actual business purpose

For the discussion in this paper, the term “abusive tax avoidance,” where MNCs clearly engage in questionable practices that go against the intention of the law when it was created to avoid paying their fair amount of taxes, will be used. This is most similar to the idea of “Toxic Avoidance” described above. To be extra clear, this is different from tax evasion; tax evasion is when the subject makes use of fake information (overstated costs, understated revenue, a cover up of assets, etc.) to pay fewer taxes (Hall 2013, 2).

However, tax avoidance is not something new. As in the opening quote above by Franklin D Roosevelt, governments have always struggled with citizens and corporations who try to reduce how much they pay in taxes to their respective governments. The problem today is that process of globalization and the rise of the multinational corporations that it creates have facilitated the practice of engaging in abusive tax avoidance. Once MNCs began to operate in several different countries, it made it easier to shift costs, revenues, and profits through different taxes jurisdictions (Silla and Willmott 2010, 343). Some examples of MNCs that are known to have been engaging in aggressive tax avoidance are Apple, Google, Starbucks, and Microsoft (Colle and Bennett 2014, 1).

Furthermore, as analyzed in Brock and Russell’s (2015) paper, globalization has allowed such corporations to make use of several instruments and practices to minimize their tax burden. Moreover, Ireland, together with some other offshore tax havens, became the epicenter of tax avoidance for MNCs around the world. In general terms, tax havens are jurisdictions that offer minimal to no tax duties in their territories. Furthermore, they usually offer banking secrecy, making it difficult for the “tax man” to find the lost revenue. In the case of Ireland, its low corporate rate (12.5%) and its definition of tax residency for corporations makes it the perfect place to be if an MNC wants to avoid paying taxes. To achieve what is called double non-taxation of profits, MNCs make use of certain strategies. In Ting’s (2014) article on tax avoidance tools used by Apple, he enumerates some of these practices such as:

  • Definitions of corporate residence in Ireland and the US
  • Transfer pricing rules on intangibles
  • Controlled foreign corporation (CFC) regime in the US
  • Check-the-box regime in the US
  • Low-tax jurisdiction

Although a detailed analysis of these examples is beyond the scope of this paper, the two main techniques to reduce the tax burden will be explained. The first practice regarding definitions of corporate residence is when an MNC has residency in both the US and Ireland. This is essential to perform the famous “Double Irish Scheme.” Colle and Bennett’s (2014) paper has a profound analysis of such subterfuge. It consists of setting up two different companies in the US and in Ireland, but under the same conglomerate. It works because Ireland considers a corporation to be taxed where its headquarters is. For the US, the tax residency is where the company is incorporated. Therefore, if a company such as Apple is incorporated in Ireland but has its headquarters in the United States, it will have virtually no tax residence anywhere.

Another well-known practice, listed as the second bullet, to avoid paying taxes is called a “pricing transfer.” This is when the subsidiary of an MNC in a low tax jurisdiction owns the intellectual property of the conglomerate and the head office in a high taxable jurisdiction then pays for the use of this intellectual property to the subsidiary, thus reducing or eliminating its taxable profit.

As mentioned above, one of the most notorious cases of tax avoidance is based on Apple’s tax management. Although Apple has been using tactics of tax avoidance for decades, it has been growing in visibility due to the increasing profits of the American company compared to the low taxes it pays. From 2009 to 2012, using some of the tax avoidance practices mentioned above, it effectively sheltered US $ 44 billion from taxation around the world (Ting 2014, 41). Moreover, as of right now, it has maintained US $ 181 billion offshore (outside the location of its main office, the United States) in order to avoid paying other billions in US corporate taxes.

For the research of this paper, much has been found in the literature regarding abusive tax avoidance and tax evasion including its moral issues, how it is happening, and what must be done to mitigate it. Papers such as “Abusive Tax Avoidance and Responsibilities of Tax Professionals,” “Does Legality Matter?,” “The Case of Tax Avoidance and Evasion,” “The Dark Side of Transfer Pricing: Its Role in Tax Avoidance and Wealth Retentiveness,” “Morality, Tax Evasion, and Equity,” and “The Ethics of Tax Avoidance and Tax Evasion,” all touch on this subject by analyzing the moral hazard of engaging in abusive tax avoidance and the tools that corporations use to do it.

In the paper “International Profit-Shifting out of Developing Countries and the Role of Tax Havens,” the authors Petr Jansky and Alex Prats discuss tax havens, as does “A Good Century for Tax Globalization, Redistribution and Tax Avoidance.” Although not a novelty, these very low tax nations are the forefront of the whole scheme of abusive tax avoidance and its use has been facilitated by globalization.

Regarding abusive tax avoidance and its connection with globalization, the literature is quite a bit more reduced. However, it is possible to find important information regarding this relationship in papers such as “International Tax Cooperation and Implications of Globalization” and “Tax Avoidance, Tax Competition and Globalization: Making Tax Justice a Focus for Global Activism.” This last paper made a call to arms back in 2004 to stop extreme tax avoidance. However, unfortunately little has been done until 2016.

Specifically about the Apple case, only one academic paper has been found to have relevant information since it is a fairly new subject: “iTax—Apple’s International Tax Structure and the Double Non-Taxation Issue.” However, since it is a current issue, there is a lot of updated information in periodicals such as Forbes, Financial Times, The Economist, The Guardian, and The New York Times.

As far as the OECD Action Plan on BEPS goes, although it is relatively new, a fair amount of academic work has been done about it, though mostly critical and offering advice on how to improve it. This can be seen in “A Call to Rewrite the Fundamentals of International Taxation: the OECD BEPS,” “Action Plan, International Tax Issues Corner,” and “The OECD BEPS Project— A Status Update.” In this last paper, the author examines updated information about the creation of a multilateral instrument suggested by the OECD that would facilitate negotiation among countries and corporations in regards to tax, double non-taxation, and tax avoidance. This is an instrument that will be part of the further examined later in this paper.

 

  1. Analysis

One can study the process of tax avoidance and its consequences with different levels of analysis in international relations: the domestic level (consumers and citizens), the national level (state governments), the supranational level (the European Commission), and in the international multilateral level by the Organization of Economic Cooperation and Development (OECD).

On the domestic level, the case of tax avoidance by MNCs can be examined in a way that highlights the social consequences of such practices. As mentioned above, taxes are the lifeline of governments. Without them, they cannot provide their citizens with the basic infrastructure, security, and welfare for a decent life. Hence, when tax revenue for a certain country are reduced due to companies operating in its territories not paying the proper amount of taxes, the ability of governments to function properly is hindered. When this process happens, usually the low-income earners of a society are the biggest losers as tax avoidance as tax avoidance leads to increased social inequality, undermines compliance culture (as in less people will feel complied to pay their fair amount of taxes), and contributes to overall global poverty since tax avoidance is a global problem (Colle and Bennett 2014, 13).

On the other hand, the winners tend to be high-income consumers. By reducing the amount of taxes they pay, MNCs can use these savings to develop new products and directly pass the savings to the consumers. Therefore, a middle to high income individual who does not depend so much on the government for social benefits may profit from more advanced and cheaper products. Moreover, advocators of individual freedom might see tax avoidance in ideological terms as nothing more than a legit practice undertaken to increase individual freedom from an oppressive government, which they believe inappropriately taxes its citizens (Colle and Bennett 2014, 11).

On the national level, much has been said about the negative effects on the governability of states that tax avoidance brings. An interesting fact is that quite a few western states, such as the US and the UK, have championed liberalism and free trade, the hallmarks of globalization. Possibly, they were not able to foreseen that liberalism and globalization would give birth to ever stronger MNCs which would then compete with a weakening state in power and influence as the main international actors. Furthermore, the third wave of globalization, which started with the end of the Cold War together with technological advances, brought unprecedented openness in production and service markets together with increasing capital flows around the globe. This process has opened the world to stiff state competition to attract MNCs and foreign direct investment (FDI). The problem arises due to the fact that there is not at the present a multilateral institution that could facilitate cooperation among states in regards to tax policy. Hence, states have engaged in harmful competition, or what is called a “race to the bottom,” by lowering their corporate tax rates in order to attract MNCs (Ndikumana 2014, 3). This beggar-thy-neighbor race has clear winners and losers. The winners are the MNCs, which can participate in tax arbitrage to search for a more beneficial tax jurisdiction and thus ending up paying less taxes. The losers on the national level are state actors who lose tax revenue in order to attract MNC investment, which then leads to another state losing the companies FDI. As stated above, the loss in the national level translates into a loss in the individual level for a great part of the population. This can lead to frustrated demands, protests, and eventually conflict.

Finally, on the international level, the lack of proper international mechanisms to combat tax avoidance has magnified the situation. However, recent initiatives undertaken by the G20 are changing this panorama. In 2013, the OECD formulated a report entitle BEPS (Base Erosion and Profit Shifting). This was in fact a response to a demand of some leaders in the G20 concerned with the erosion of tax revenue due to tax avoidance practices by MNCs (Jansky and Pratts 2015, 271). The report concluded that the existing international tax system, characterized by tax competition between states as opposed to cooperation among them, has not followed the pace of a globalized economy and the strength and reach of MNCs. This has provided MNCs with a lot of opportunities to engage in tax arbitration and to exploit legal loopholes to reduce their tax burden (Jansky and Pratts 2015, 272).

However, the same BEPS report came two years later with an Action Plan report where the OECD established 15 actions that should be undertaken by governments and international organizations to combat international tax avoidance. Although, while the details of such plans are not in the scope of this paper, it is important to highlight action plan item 15. It calls for the development of a multilateral instrument “…. designed to provide an innovative approach to international tax matters, reflecting the rapidly evolving nature of the global economy and the need to adapt quickly to this evolution” (OECD 2015, 24). In other words, the OECD (a multilateral institution itself) produced a report where it suggested the creation of another multilateral instrument to facilitate cooperation among nation states. Hence, although some of the main characteristics of liberalism – free trade, and free capital flow through open markets – have exacerbated the issue with tax avoidance, the same liberalism mentality has facilitated the dialogue and cooperation of governments at the supranational level to solve a global problem.

Another action taken at the supranational level was by the United Nations Tax Committee whose objective was to explore the possible evolution towards a unitary taxation of MNCs with profit apportionment by country that would make the international tax system fairer (Office UN, 2016). Finally, the latest ruling by the European Commission on Apple’s tax avoidance case emphasizes the possible effectiveness of supranational actors in the case of abusive tax avoidance (“Apple Faces Multibillion Tax Bill In EU Rulling,” 2016). The European Commission has ruled that Apple should pay almost US $ 15 billion in taxes back to Ireland. At the same time, Ireland, who ought to be content to be receiving such an amount, protested this decision (mostly because it takes away the country’s attractiveness to MNCs and thus FDI). Hence, it is possible to observe a conflict between an actor at the state level (Ireland) and a supranational actor at the international level (EU Commission). Although the final decision will mostly be defined by the courts, it gives a hint as to what the relationship between national and international actors might be in the future in regards to tax policy of MNCs.

 

  1. Implication on the IPE ideologies

In regards to IPE ideologies, liberalism has already been analyzed in the previous segments. Abusive tax avoidance is a direct consequence of free trade and the liberalization of capital flows defended by liberalism ideology. The smaller role played by nation states in a globalized economy had negative consequences at both the national and individual level. Nevertheless, the same ideology has permitted the formation (or possible creation) of multilateral institutions in order to tackle the problem.

However, seeing the issue through a mercantilist lens gives the reader a different perspective. By preaching a state centered approach, mercantilism might be at the source of the problem. Instead of cooperating in tax issues, states kept their state-centered mentality of survival and beggar-thy-neighbor competition rather than collaboration. Moreover, as in Game Theory, instead of collaborating to reach a better outcome, the lack of adequate international institutions to forge trust among them has led to the worst outcome with less “power and wealth” to the state ultimately, which is exactly the opposite of the main objective of mercantilism.

Finally, Marxism ideology would see abusive tax avoidance by MNCs (mostly from the global north or “core” countries) as another example of exploitation of the developing countries (global south or “periphery” countries). The examples of MNCs given above are all from the United States, the definition of a capitalist “core” country. Moreover, some papers from the literature have pointed out this pernicious relationship between MNCs and developing countries. In Ndikumana’s (2014) paper, the author examines the links between globalization and taxation and their consequences. One of them is the concern that globalization does not benefit all players equally. He points out that the least developed countries (LDCs) are substantially underprivileged in the allocation of capital and savings. Particularly, least developed countries suffer sizable losses in tax revenue due to profit shifting (a form of tax avoidance mentioned above) by MNCs operating in their territories (Ndikumana 2014, 3).

Furthermore, the same author stresses the role of tax havens, which by helping MNCs funneling precious tax resources out of LDCs to themselves, deprive these developing countries of precious tax revenues. This in turn will lead to fewer resources for the welfare of the citizens, flawed income distribution, and thus a permanent state of social inequality. This process would prove Marxist theories that the international economic system is nothing more than a perpetuation of the exploitation by rich countries and their MNCs of the resources of the least developed countries.

To conclude on how Marxist ideology might perceive abusive tax avoidance by MNCs, the paper by Jansky and Pratts (2015) studies the behavior of more than 1,500 MNCs (mostly from the rich North) operating in India. It concluded that in 2010, MNCs with subsidiaries in tax havens used profit-shifting mechanism from the Asian country to such tax haven subsidiaries. This process led the MNCs to report lower profits in India when compared with MNCs without presence in tax havens. This way, MNCs could reduce their tax burden, striping a country with a population beyond 1 billion people of valuable resources that could have been used in the welfare of its majority-poor population (Jansky and Pratts 2015, 275).

 

  1. Conclusion and Policy Implications

Since the end of Cold War, globalization has taken pace and today is defining how MNCs do business around the world. Some MNCs have their headquarters in US, their finance center in London, their customer service in India, and their production in China. This extreme internationalization of MNCs has not been followed by proper mechanisms from nation states to effectively tax such conglomerates. By realizing such deficiency in national tax systems, MNCs have taken advantage of ambiguities, loopholes and grey areas in the tax system of some countries to avoid paying their fair share of taxes. What before was just seeing as tax mitigation has now turned into the formation of complex corporate structures with the sole objective of avoiding paying taxes to national governments. To do this, MNCs make use of tax heavens and lower tax jurisdiction such as Ireland. Once they have subsidiaries in such regions, corporations operate complex fiscal tools to avoid taxes. Profit-shifting, “the Double Irish,” and others are instruments used to reduce their tax liabilities.

            The main issue with such practices by MNCs is that there are economic and social consequences. Developed and developing countries lose tax revenue which otherwise would be used to supply services to their citizens. By stripping governments of such income, MNCs are weakening national governments by damaging their power to manage society in an ideal form. Moreover, the society itself loses these benefits, thus increasing poverty and inequality. Therefore, tax avoidance has consequences at the individual level as well as the national one. However, based on the literature in the subject, the international level of analysis is the most interesting one since most of the solutions for such a problem are related to cooperation among national states facilitated by multilateral organizations. To this date, this seems to be one of the most promising solutions for the growth in tax avoidance around the world.

            To conclude, tax avoidance was examined by all three international political economy ideologies. For Marxism, tax avoidance proves the facet of exploitation within the international economic system. Mercantilists have seen their state power threatened by the growing and dominant MNCs and they will have to realize that they cannot just think state survival anymore. The only way to even out again the power of state actors with MNCs in a globalized world is to follow the liberalism ideas of cooperation in the international sphere and the creation of multilateral structures to assist with collaboration. The creation of the BEPS Action Plan by the OECD has followed this path and, together with the actions of the European Commission in Apple’s case, might become the norm instead of the exception for the way the world deals with abusive tax avoidance by MNCs.

To read the proposal paper: http://globalpoliticalstudies.com/abusive-tax-avoidance-and-globalization/

 

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