A new framework to assess the fiscal impact of a global minimum tax on FDI
137
Profit shifting matrix based on Heckemeyer and Overesch (2017)
The tax semi-elasticity approach hinges on the meta-study of Heckemeyer and
Overesch (2017) and is used in Devereux et al. (2020) and Hanappi and Cabral
(2020), among others.
Heckemeyer and Overesch (2017) find that the tax semi-elasticity of (pre-tax)
reported profits is equal to 0.8.
In other words, reported profits in country c
decrease by 0.8 per cent if the tax rate in c increases by 1 pp. Country-level profit
shifting shares
γ
c
are thus calibrated as follows:
γ
ch
=
PS
O
ch
ψ
c
Π
∗
c
+
h
=
c
PS
O
ch
γ
c
=
max
0.8
×
ETR
c
−
ETR
h
,
0
γ
ch
=
γ
c
FDI
ch
h
,
h
=
c
FDI
ch
5
where
ETR
h
is the average ETR in OFCs. Country-level profit shifting shares are
then transformed into bilateral profit shifting shares using data on FDI from non-
OFC countries in OFCs:
γ
ch
=
PS
O
ch
ψ
c
Π
∗
c
+
h
=
c
PS
O
ch
γ
c
=
max
0.8
×
ETR
c
−
ETR
h
,
0
γ
ch
=
γ
c
FDI
ch
h
,
h
=
c
FDI
ch
5
FDI data come from the International Monetary Fund (IMF) Coordinated Direct
Investment Survey (CDIS) database (accessed 31 December 2021), which
incorporates 127 countries.
Ratios
γ
ch
=
PS
O
ch
ψ
c
Π
∗
c
+
h
=
c
PS
O
ch
γ
c
=
max
0.8
×
ETR
c
−
ETR
h
,
0
γ
ch
=
γ
c
FDI
ch
h
,
h
=
c
FDI
ch
5
for non-OFCs missing from the IMF
CDIS database are replaced with global averages. It is worth noting that this
calibration procedure does not require an econometric model.
139
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