Multinational enterprises, value creation and taxation: Key issues and policy developments

03-07-2019

The substantial reduction in trade costs and the rapid technological advances characterising the global economy over the past three decades have allowed multinational enterprises (MNEs) to increasingly break up their supply chains and spread them across different countries. The principal implication of this change relates to the concept of value added and the way it is created and captured across MNE-controlled global value chains (GVCs). The dynamic nature of transfers within MNEs, the increasing role of services and intangible assets in manufacturing, and most critically the unfolding digital revolution have all intensified the mobility of value-generating factors within GVCs, and highlighted the difficulty of defining the exact location where value is generated. These developments have significant policy implications. One critical area is that of tax policy, where the challenges posed by the new economic landscape are numerous and multifaceted. On the one hand, governments seek to encourage trade and investment by MNEs by removing tax and regulatory barriers they face. Some governments go even further by resorting to harmful tax competition that drives corporate income taxes to the bottom. At the same time, many MNEs continue to employ enhanced tax arbitrage to minimise their tax obligations across jurisdictions; furthermore, business models are increasingly becoming borderless and highly mobile, and therefore difficult to tax. In view of these challenges, consensus is gradually emerging that tax systems need improved alignment to ensure that profits are taxed where the economic activities generating them are performed and where value is created. Yet, allocating jurisdiction to tax business profits in the context of MNE-controlled GVCs remains a highly complex process.

The substantial reduction in trade costs and the rapid technological advances characterising the global economy over the past three decades have allowed multinational enterprises (MNEs) to increasingly break up their supply chains and spread them across different countries. The principal implication of this change relates to the concept of value added and the way it is created and captured across MNE-controlled global value chains (GVCs). The dynamic nature of transfers within MNEs, the increasing role of services and intangible assets in manufacturing, and most critically the unfolding digital revolution have all intensified the mobility of value-generating factors within GVCs, and highlighted the difficulty of defining the exact location where value is generated. These developments have significant policy implications. One critical area is that of tax policy, where the challenges posed by the new economic landscape are numerous and multifaceted. On the one hand, governments seek to encourage trade and investment by MNEs by removing tax and regulatory barriers they face. Some governments go even further by resorting to harmful tax competition that drives corporate income taxes to the bottom. At the same time, many MNEs continue to employ enhanced tax arbitrage to minimise their tax obligations across jurisdictions; furthermore, business models are increasingly becoming borderless and highly mobile, and therefore difficult to tax. In view of these challenges, consensus is gradually emerging that tax systems need improved alignment to ensure that profits are taxed where the economic activities generating them are performed and where value is created. Yet, allocating jurisdiction to tax business profits in the context of MNE-controlled GVCs remains a highly complex process.