In the global economy, the intermediate companies owned by multinational corporations are becoming an important policy issue as they are likely to cause international profit shifting and diversion of foreign direct investments. The purpose of this analysis is to call the intermediate companies with high risk of international profit shifting as key firms and to identifying and clarify them. For this aim, we propose a model that focuses on each affiliate's position on the ownership structure of each multinational corporation. Based on the information contained in the Orbis database, we constructed the Global Ownership Network, reflecting the relationship that can give significant influence to a firm, and analyzed for large multinational corporations listed in Fortune Global 500. In this analysis, first, we confirmed the validity of this model by identifying affiliates playing an important role in international tax avoidance at a certain degree. Secondly, intermediate companies are mainly found in the Netherlands and the United Kingdom, etc., and tended to be located in jurisdictions favorable to treaty shopping. And it was found that such key firms are concentrated on the IN component of the bow-tie structure that the giant weakly connected component of the Global Ownership Network consist of. Therefore, it clarifies that the key firms are geographically located in specific jurisdictions, and concentrates on specific components in the Global Ownership Network. The location of key firms are related with the ease of treaty shopping, and there is a difference in the jurisdiction where key firms are located depending on the location of the multinational corporations.
Currently all countries including developing countries are expected to utilize their own tax revenues and carry out their own development for solving poverty in their countries. However, developing countries cannot earn tax revenues like developed countries partly because they do not have effective countermeasures against international tax avoidance. Our analysis focuses on treaty shopping among various ways to conduct international tax avoidance because tax revenues of developing countries have been heavily damaged through treaty shopping. To analyze the location and sector of conduit firms likely to be used for treaty shopping, we constructed a multilayer ownership-tax network and proposed multilayer centrality. Because multilayer centrality can consider not only the value flowing in the ownership network but also the withholding tax rate, it is expected to grasp precisely the locations and sectors of conduit firms established for the purpose of treaty shopping. Our analysis shows that firms in the sectors of Finance & Insurance and Wholesale & Retail trade etc. are involved with treaty shopping. We suggest that developing countries make a clause focusing on these sectors in the tax treaties they conclude.
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