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What Drives Profit Shifting? Evidence from Macroeconomic Cross-Country Data

This paper utilizes macro-level data from 64 countries to demonstrate that profit shifting is primarily driven by institutional, regulatory, and cultural factors rather than standard economic fundamentals, with transparency policies like Country-by-Country reporting proving effective while higher government effectiveness paradoxically correlates with increased shifting due to sophisticated planning strategies.

Original authors: Katarzyna Perez, Katarzyna Schmidt-Jessa, Tomasz Kaczmarek

Published 2026-07-10
📖 5 min read🧠 Deep dive

Original authors: Katarzyna Perez, Katarzyna Schmidt-Jessa, Tomasz Kaczmarek

Original paper licensed under CC BY 4.0 (https://creativecommons.org/licenses/by/4.0/). This is an AI-generated explanation of the paper below. It is not written or endorsed by the authors. For technical accuracy, refer to the original paper. Read full disclaimer

Imagine the global economy as a giant, bustling marketplace where massive companies (multinational enterprises) set up shop in dozens of different countries. These companies have a tricky habit: they try to move their "profits" (the money they make) from countries where taxes are high to countries where taxes are low, kind of like a magician making a coin disappear from one hand and reappear in another. This is called profit shifting.

For a long time, people thought this magic trick was driven by simple math: big markets, fast growth, or lots of trade. But this new study, looking at data from 64 countries between 2009 and 2022, pulls back the curtain to show that the real drivers are much more complex and surprising.

The Big Reveal: It's Not About the Size of the Market

The researchers first checked if the usual suspects were to blame. They looked at how big a country's economy is, how fast it's growing, and how open it is to trade. The study rules these out. It turns out that having a huge market or a booming economy doesn't automatically make a country a magnet for shifted profits. The "magic" isn't happening because of basic economic fundamentals.

The Real Culprits: Rules, Transparency, and "Vibes"

Instead of economics, the study finds that profit shifting is driven by three specific things: Institutions, Regulations, and Culture.

1. The "Glass House" Effect (Transparency)
Imagine a company trying to hide a secret stash of money in a dark closet. If you suddenly install a giant, bright window in that closet, the secret is much harder to keep.
The study found that when countries adopt Country-by-Country (CbC) reporting, profit shifting drops significantly. This is a rule where companies must publish a report showing exactly how much money they make and pay in taxes in every country they operate.

  • The Finding: The paper shows that countries with this "glass house" policy have significantly lower levels of profit shifting. It suggests that just making the information visible is a powerful tool to stop the hiding game.

2. The "Sophisticated Planner" Paradox (Government Effectiveness)
Here is the twist that might make you scratch your head. You might think that a government that works well (high "Government Effectiveness") would catch tax dodgers and stop them.

  • The Finding: The study actually found the opposite. Countries with higher Government Effectiveness are linked to greater profit shifting.
  • Why? The authors suggest that in countries with very stable, efficient, and predictable systems, companies don't just break the rules; they get really good at playing by them in clever ways. Strong institutions create a safe, stable environment where companies can build incredibly complex, legal-sounding financial structures to move their money. It's like having a master chess player in a country with perfect rules; they don't break the rules, they just find the most brilliant, loophole-filled moves that are hard for anyone to stop.

3. The "Cultural Vibe" (Religion)
The study also looked at the "vibe" of a country, using the dominant religion as a proxy for social norms and how much people care about following rules (tax morale).

  • The Finding: When looked at one by one, countries with a dominant Christian affiliation showed higher levels of profit shifting, while countries with a dominant Islamic affiliation showed lower levels.
  • The Catch: The paper is careful to say this is suggested by the data, but it gets fuzzy when you look at both religions at the same time. It's not a hard-and-fast rule like a law, but rather a hint that social norms and what people believe about "doing the right thing" might nudge companies toward or away from aggressive tax planning.

What About the Tax Rate Itself?

You might wonder, "What about the actual tax rate? Do companies just run to the cheapest place?"
The study suggests that while tax rates matter, they aren't the whole story. The researchers included the statutory corporate tax rate in their models, but it didn't show up as a strong, consistent driver in the way they expected. The "sophistication" of the rules and the transparency of the system seem to matter more than just the raw number on the tax bill.

How Sure Are We?

The authors are pretty confident in their main findings. They used a massive dataset covering 840 observations and ran the numbers through strict statistical tests to make sure the results weren't just a fluke.

  • They checked if the results held up if they changed the assumed tax rate (trying 15%, 20%, and 25%). The results stayed the same.
  • They checked if a few weird countries were messing up the data. Even when they removed the outliers, the results stayed the same.
  • They checked if the "Government Effectiveness" finding was just a coincidence. It held up.

The Takeaway

So, if you want to stop companies from playing hide-and-seek with their profits, simply lowering or raising tax rates isn't the silver bullet. The study suggests that the best tools are:

  1. Shining a light: Making companies show their work (transparency).
  2. Understanding the game: Realizing that strong, efficient governments might accidentally make it easier for companies to get too clever with their planning.
  3. Watching the culture: Recognizing that what a society values (its norms and morals) plays a quiet but real role in how companies behave.

The paper doesn't claim to have "solved" the problem, but it gives us a much clearer map of where the real drivers are hiding. It suggests that to fix the system, we need to look beyond the math and focus on the rules, the transparency, and the culture of the countries involved.

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