Tax haven - Knowledge

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contain more fundamental reforms to corporate taxation around the taxing of profits where a product is consumed, rather than where the product's value is created (as currently done). Although the EU had been a long-term advocate of this concept, the US had traditionally blocked it. However, it is believed the passing of the 2017 TCJA has changed Washington's view on US corporate use of tax havens, who still remain the largest users of tax havens in the world. In response to this new OECD initiative, the EU, and the French in particular, dropped their "Digital Tax" proposal in favour of allowing the OECD BEPS 2.0 initiative reach a conclusion, which it is scheduled to do by 2020.

5247: 2643:, most of these tax havens date from the late 1960s and effectively copied the structures and services of the above groups. Most of these tax havens are not OECD members, or in the case of British Empire–related tax havens, do not have a senior OECD member at their core. Some have suffered setbacks during various OECD initiatives to curb tax havens (e.g. Vanuatu and Samoa). However, others such as Taiwan (for AsiaPAC), and Mauritius (for Africa), have grown materially in the past decades. Taiwan has been described as "Switzerland of Asia", with a focus on secrecy. Although no Emerging market-related tax haven ranks in the five major global Conduit OFCs or any 3224: 2582:, the first recognized tax haven hub was the Zurich-Zug-Liechtenstein triangle created in the mid-1920s, later joined by Luxembourg in 1929. Privacy and secrecy were established as an important aspect of European tax havens. However, modern European tax havens also include corporate-focussed tax havens, which maintain higher levels of OECD transparency, such as the Netherlands and Ireland. European tax havens act as an important part of the global flows to tax havens, with three of the five major global Conduit OFCs being European (e.g. the Netherlands, Switzerland, and Ireland). Four European-related tax havens appear in the various notable 1995:(1966), a self-governing external territory of Australia. It was followed by Vanuatu (1970–71), Nauru (1972), the Cook Islands (1981), Tonga (1984), Samoa (1988), the Marshall Islands (1990), and Nauru (1994). All these havens introduced familiar legislation modeled on the successful British Empire and European tax havens, including near-zero taxation for exempt companies, and non-residential companies, Swiss-style bank secrecy laws, trust companies laws, offshore insurance laws, flags of convenience for shipping fleets and aircraft leasing, and beneficial regulations for new online services (e.g. gambling, pornography, etc.). 5510: 5031: 3732: 5709:, an information standard for the automatic exchange of tax and financial information on a global level (which would already be needed by FATCA to process data). Participating in the CRS from 2017 onwards are Australia, the Bahamas, Bahrain, Bermuda, Brazil, British Virgin Islands, Brunei Darussalam, Canada, Cayman Islands, Chile, China, the Cook Islands, Guernsey, Hong Kong, Indonesia, Israel, Japan, Jersey, Kuwait, Lebanon, Macau, Malaysia, Mauritius, Monaco, New Zealand, Panama, Qatar, Russia, Saudi Arabia, Singapore, Switzerland, Turkey, the United Arab Emirates, and Uruguay. 4579: 4243: 4537: 4222: 5421:(ICIJ) released a searchable 260 gigabyte database of 2.5 million tax haven client files anonymously leaked to the ICIJ and analyzed with 112 journalists in 58 countries. The majority of clients came from mainland China, Hong Kong, Taiwan, the Russian Federation, and former Soviet republics; with the British Virgin Islands identified as the most important tax haven for Chinese clients, and Cyprus an important tax haven location for Russian clients. Various prominent names were contained in the leaks including: 2556:("FSI") and the term "secrecy jurisdiction", to highlight issues in regard to OECD-compliant countries who have high tax rates and do not appear on academic lists of tax havens, but have transparency issues. The FSI does not assess tax rates or BEPS flows in its calculation; but it is often misinterpreted as a tax haven definition in the financial media, particularly when it lists the US and Germany as major "secrecy jurisdictions". However, many types of tax havens also rank as secrecy jurisdictions. 4707: 4350: 4644: 4308: 5191:" is where the corporate overcomes IRS 7874 by merging with a corporation that has a "substantive business presence" in the new location. The requirement for a substantive business presence meant that US corporations could only invert to larger tax havens, and particularly OECD tax havens and EU tax havens. Further tightening of regulations by the US Treasury in 2016, as well as the 2017 TCJA US tax reform, reduced the tax benefits of a US corporation inverting to a tax haven. 4665: 4329: 6140: 17589: 4451: 4287: 4096: 5576:(SZ). As with the Panama Papers in 2015, SZ worked with the ICIJ and over 100 media organizations to process the documents. They contain the names of more than 120,000 people and companies including Apple, AIG, Prince Charles, Queen Elizabeth II, the President of Colombia Juan Manuel Santos, and then-U.S. Secretary of Commerce Wilbur Ross. At 1.4 terabytes in size, this is second only to the Panama Papers of 2016 as the biggest data leak in history. 5234:) is well understood and accepted. However, IP enables a corporation to "revalue" its costs dramatically. For example, a major piece of software might have cost US$ 1 billion to develop in salaries and overheads. IP accounting enables the legal ownership of the software to be relocated to a tax haven where it can be revalued to being worth US$ 100 billion, which becomes the new price at which it is charged out against global profits. This creates a 4622: 4495: 4265: 4117: 5070:

of untaxed offshore profits built up by U.S. multinationals with BEPS tools from non-U.S. revenues. Had these U.S. multinationals paid taxes on these non-U.S. profits in the countries in which they were earned, there would have been the little further liability to U.S. taxation. Research by Zucman and Wright (2018) estimated that most of the TCJA repatriation benefit went to the shareholders of U.S. multinationals, and not the U.S. exchequer.

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their assets, foreign citizens legally resident in the UK pay no taxes on their global assets, as long as they are left outside the UK; thus, for a foreign resident, the UK behaves in a similar way to a traditional tax haven. Some tax academics say that PTRs make the distinction with traditional tax havens "matter of degree more than anything else". The OECD has made the investigation of PTRs a key part of its long-term project of combatting

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regulations that enabled U.S. multinationals to avoid some of these rules by electing to treat their foreign subsidiaries as if they were not corporations but disregarded entities for tax purposes. This move is called "checking the box" because that is all that needs to be done on IRS form 8832 to make it work and use Irish BEPS tools on non-U.S. revenues was a compromise to keep U.S. multinationals from leaving the U.S. (page 10.)

4600: 4180: 4473: 4430: 4074: 4052: 5219:, in 2017, the OECD estimated that BEPS tools shielded US$ 100 to US$ 200 billion in annual corporate profits from tax; while in 2018, Zucman estimated that the figure was closer to US$ 250 billion per annum. This was despite the 2012–2016 OECD BEPS Project. In 2015, Apple executed the largest recorded BEPS transaction in history when it moved US$ 300 billion of its IP to Ireland, in what was called a hybrid-tax inversion. 17600: 5448:

Luxembourg. This ICIJ investigation disclosed 548 tax rulings for over 340 multinational companies based in Luxembourg. The LuxLeaks' disclosures attracted international attention and comment about corporate tax avoidance schemes in Luxembourg and elsewhere. This scandal contributed to the implementation of measures aiming at reducing tax dumping and regulating tax avoidance schemes beneficial to multinational companies.

1652: 15817: 4770: 6049:, their report noted that Apple had been using the structure from at least as far back as 1991. Several Senate and congressional inquiries in Washington cited public knowledge of the Double Irish from 2000 onwards. However, it was not the US who finally forced Ireland to close the structure in 2015, but the EU Commission; and existing users were given until 2020 to find alternative arrangements, two of which (e.g. 5675:. Starting January 2014, FATCA requires FFIs to provide annual reports to the IRS on the name and address of each U.S. client, as well as the largest account balance in the year and total debits and credits of any account owned by a U.S. person. In addition, FATCA requires any foreign company not listed on a stock exchange or any foreign partnership which has 10% U.S. ownership to report to the IRS the names and 6037:. The OECD BEPS Multilateral Instrument ("MLI"), was adopted on 24 November 2016 and has since been signed by over 78 jurisdictions; it came into force in July 2018. The MLI has been criticised for "watering down" several of its proposed initiatives, including country–by–country–reporting ("CbCr"), and for providing several opt-outs which several OECD and EU tax havens availed of. The US did not sign the MLI. 1876:, backed a plan by a New York lawyer, Mr. Dill, to create a more liberal regime for establishing corporate structures, including availability "off-the-shelf companies" (but not non-resident companies). Delaware followed with the General Incorporation Act in 1898, on the basis of lobbying from other New York lawyers. Because of the restrictive incorporation regime in the Anglo-Saxon world as a result of the 2486:, which he had scaled quantitatively by analysing corporate investment flows. Hines' largest havens were dominated by corporate tax havens, who Dharmapala noted in 2014 accounted for the bulk of global tax haven activity from BEPS tools. The Hines 2010 list was the first to estimate the ten largest global tax havens, only two of which, Jersey and the British Virgin Islands, were on the OECD's 2000 list. 2018:

larger wave of US corporate "merger inversions" started that involved moving to OECD tax havens. A new class of corporate tax haven had emerged that was OECD-compliant, transparent, but offered complex base erosion and profit shifting (BEPS) tools that could achieve net tax rates similar to traditional tax havens. Initiatives by the OECD to curb tax havens would mainly impact Palan's third group of

2540:, as Google, Facebook and Apple do not appear on Orbis. Even so, Zucman's 2018 list of top 10 havens also matched 9 of the top 10 havens in Hines' 2010 list, but with Ireland as the largest global haven. These lists (Hines 2010, CORPNET 2017 and Zucman 2018), and others, which followed a purely quantitive approach, showed a firm consensus around the largest corporate tax havens. 1761:. CRS countries require banks and other entities to identify the residence of account holders, beneficial owners of corporate entities and record yearly account balances and communicate such information to local tax agencies, which will report back to tax agencies where account holders or beneficial owners of corporations reside. CRS intends to end offshore financial secrecy and 11296: 9657: 2030:, and included the Netherlands, Singapore, Ireland, USA and the U.K., and even reformed traditional tax havens such as Luxembourg, Hong Kong, the Caribbean (the Cayman, Bermuda, and the British Virgin Islands), and Switzerland. The scale of their BEPS activities meant that this group of 10 jurisdictions would dominate academic tax haven lists from 2010, including 5532:(SZ). Given the unprecedented scale of the data, SZ worked with the ICIJ, as well as Journalists from 107 media organizations in 80 countries who analyzed the documents. After more than a year of analysis, the first news stories were published on 3 April 2016. The documents named prominent public figures from around the globe including British prime minister 5932:, called Ireland and the Netherlands, "tax black holes". After only a few months the EU reduced the blacklist further, and by November 2018, it contained only five jurisdictions: American Samoa, Guam, Samoa, Trinidad & Tobago, and the US Virgin Islands. However, by March 2019, the EU blacklist was expanded to 15 jurisdictions including Bermuda, a 3063:. The United Kingdom was not a tax haven in 1994, and Hines estimated the Netherlands's effective tax rate in 1994 at over 20%. (Hines identified Ireland as having the lowest effective tax rate at 4%.) Four of these: Ireland, Singapore, Switzerland (3 of the 5 top Conduit OFCs), and Hong Kong (a top 5 Sink OFC), featured in the Hines–Rice 1994 list's 9937: 2769:– A "sense-check" of a tax haven is whether individuals or entities redomicile themselves into a lower tax jurisdiction to legally avoid high US corporate tax rates, and additionally because of the advantage for a multinational company to be based in a territorial tax regime such as Ireland. The top 3 destinations for all U.S. corporate 6106:(TCJA), which reduced the US headline corporate tax rate from 35% to 21%, changed the US corporate tax code from a "worldwide tax system" to a hybrid–"territorial tax system", and created new IP-based BEPS tools such as the FDII tax, as well as other anti-BEPS tools such as the BEAT tax. In advocating for the TCJA, the President's 12646: 11288: 9649: 2462:' observation that the accounting flows from BEPS tools are "out-of-proportion" and thus distort the economic statistics of the haven. The FSF–IMF list captured new corporate tax havens, such as the Netherlands, which Hines considered too small in 1994. In April 2007, the IMF used a more quantitative approach to generate a 4974:, "Treasure Islands", where he showed how U.S. multinationals used tax havens and BEPS tools to avoid Japanese taxes on their Japanese investments, noted that this was being confirmed by other empirical research at a company-level. Hines's observations would influence U.S. policy towards tax havens, including the 1996 " 4869:

tax haven research, such as Hines, Dharmapala, and others, cite evidence that, in certain cases, tax havens appear to promote economic growth in higher-tax countries, and can support beneficial hybrid tax regimes of higher taxes on domestic activity, but lower taxes on international sourced capital or income:

1726:(FSI) rankings, can be featured in some tax haven lists, they are often omitted from lists for political reasons or through lack of subject matter knowledge. In contrast, countries with lower levels of secrecy but also low "effective" rates of taxation, most notably Ireland in the FSI rankings, appear in most 13641:"the captured state": a world in which policymaking has been largely taken over by financial interests that can pick and choose between jurisdictions and in effect write the laws they need. "That happens in its purest form in the very small tax havens where there is just no local democracy to do anything. 5319:, which are the jurisdictions that create the OECD-compliant tax structures that enable the untaxed funds to be routed from the higher-tax jurisdictions to the Sink OFCs. Despite following a purely quantitative approach, CORPNET's top 5 Conduit OFCs and top 5 Sink OFCs closely match the other academic 15458:

Brussels is challenging the "Double Irish" tax avoidance measure prized by big U.S. tech and pharma groups, putting pressure on Dublin to close it down or face a full-blown investigation. The initial enquiries have signalled that Brussels wants Dublin to call time on the tax gambit, which has helped

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Some economists champion tax havens. In an article in the Journal of Economic Perspectives published last fall (also titled "Treasure Islands"), James R. Hines Jr. of the University of Michigan argued that they contribute to financial market competition, encourage investment in high-tax countries and

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Zucman and Wright's analysis assumed that U.S. multinationals were going to pay a U.S. 35% rate eventually (e.g. they would repatriate their untaxed offshore cash at some stage in the future); if the assumption is made that they were going to permanently leave their offshore cash outside of the U.S.,

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groups interpreted Hines' research as the U.S. engaging in tax competition with higher-tax nations (i.e. the U.S. exchequer earning excess taxes at the expense of others). The 2017 TCJA seems to support this view with the U.S. exchequer being able to levy a 15.5% repatriation tax on over $ 1 trillion

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U.S. multinationals use tax havens more than multinationals from other countries which have kept their controlled foreign corporations regulations. No other non-haven OECD country records as high a share of foreign profits booked in tax havens as the United States. This suggests that half of all the

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A controversial area of research into tax havens is the suggestion that tax havens actually promote global economic growth by solving perceived issues in the tax regimes of higher-taxed nations (e.g. the above discussion on the U.S. "worldwide" tax system as an example). Important academic leaders in

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published joint research between the IMF and tax academics titled, "Piercing the Veil", that estimated circa US$ 12 trillion in global corporate investment worldwide was "just phantom corporate investment" structured to avoid corporate taxation, and was concentrated in eight major locations. In 2019,

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Zucman followed up his 2015 book with several co-authored papers that focused on corporate use of tax havens, titled "The Missing Profits of Nations" (2016–2018), and "The Exorbitant Tax Privilege" (2018), which showed that corporations, shield over US$ 250 billion per annum from taxes. Zucman showed

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Henry's credibility and the depth of this analysis meant that the report attracted international attention. The TJN supplemented his report with another report on the consequences of the analysis in terms of global inequality and lost revenues to developing economies. The report was criticised by a

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Post–2010 research on tax havens is focused on quantitative analysis (which can be ranked), and tends to ignore very small tax havens where data is limited as the haven is used for individual tax avoidance rather than corporate tax avoidance. The last credible broad unranked list of global tax havens

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The 1998 OECD definition is most frequently invoked by the "OECD tax havens". However, that definition (as noted above) lost credibility when, in 2017, under its parameters, only Trinidad & Tobago qualified as a tax haven and has since been largely discounted by tax haven academics, including the

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In December 2008, Dharmapala wrote that the OECD process had removed much of the need to include "bank secrecy" in any definition of a tax haven and that it was now "first and foremost, low or zero corporate tax rates", and this has become the general "financial dictionary" definition of a tax haven.

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TAX HAVENS: 1.Andorra 2.Anguilla 3.Antigua and Barbuda 4.Aruba 5.Bahamas 6.Bahrain 7.Barbados 8.Belize 9.British Virgin Islands 10.Cook Islands 11.Dominica 12.Gibraltar 13.Grenada 14.Guernsey 15.Isle of Man 16.Jersey 17.Liberia 18.Liechtenstein 19.Maldives 20.Marshall Islands 21.Monaco 22.Montserrat

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Before 1996, the United States, like other high-income countries, had anti-avoidance rules—known as "controlled foreign corporations" provisions—designed to immediately tax in the United States some foreign income (such as royalties and interest) conducive of profit shifting. In 1996, the IRS issued

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In January 2019, the OECD released a policy note regarding new proposals to combat the BEPS activities of multinationals, which commentators labeled "BEPS 2.0". In its press release, the OECD announced its proposals had the backing of the U.S., as well as China, Brazil, and India. The new proposals

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Tax havens change the nature of tax competition among other countries, very possibly permitting them to sustain high domestic tax rates that are effectively mitigated for mobile international investors whose transactions are routed through tax havens. In fact, countries that lie close to tax havens

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The artificial inflation of GDP can attract underpriced foreign capital (who use the "headline" Debt-to-GDP metric of the haven), thus producing phases of stronger economic growth. However, the increased leverage leads to more severe credit cycles, particularly where the artificial nature of the GDP

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A 2022 study by Zucman and co-authors estimated that 36% of the profits of multinational firms are shifted to tax havens. If the profits had been reallocated to their domestic source, "domestic profits would increase by about 20% in high-tax European Union countries, 10% in the United States, and 5%

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In April 1998, the OECD produced a definition of a tax haven, as meeting "three of four" criteria. It was produced as part of their "Harmful Tax Competition: An Emerging Global Issue" initiative. By 2000, when the OECD published their first list of tax havens, it included no OECD member countries as

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1934: As a reaction to the global depression, the Swiss Banking Act of 1934 put bank secrecy under Swiss criminal law. The law required "absolute silence in respect to a professional secret" (i.e. accounts in Swiss banks). "Absolute" means protection from any government, including the Swiss. The law

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include corporate-focused havens like the Netherlands, Singapore, Ireland, and the U.K., while Luxembourg, Hong Kong, the Cayman Islands, Bermuda, the British Virgin Islands, and Switzerland feature as both major traditional tax havens and major corporate tax havens. Corporate tax havens often serve

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Germany taxes only 5% of the active foreign business profits of its resident corporations. Furthermore, German firms do not have incentives to structure their foreign operations in ways that avoid repatriating income. Therefore, the tax incentives for German firms to establish tax haven affiliates

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According to economics professor James Hines, tax havens serve as healthy competition for high-tax countries, nudging them toward less-restrictive financial policy. By providing alternatives to tightly controlled financial sectors, Hines wrote in a 2010 paper, tax havens discourage regulations that

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Tax havens are low-tax jurisdictions that offer businesses and individuals opportunities for tax avoidance. They attract disproportionate shares of world foreign direct investment, and, largely as a consequence, their economies have grown much more rapidly than the world as a whole over the past 25

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Those countries in the bottom tier were initially classified as being 'non-cooperative tax havens'. Uruguay was initially classified as being uncooperative. However, upon appeal the OECD stated that it did meet tax transparency rules and thus moved it up. The Philippines took steps to remove itself

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Regrets the lack of democratic accountability in the process of drawing up the "EU list of non-cooperative jurisdictions for tax purposes"; recalls that the Council seems sometimes to be guided by diplomatic or political motives rather than objective assessments when deciding to move countries from

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Other tax havens, for example in Europe or Asia, maintain higher non-zero "headline" rates of corporate taxation, but instead provide complex and confidential BEPS tools and PTRs which bring the "effective" corporate tax rate closer to zero; they all feature prominently in the leading jurisdictions

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Well over half the profits that American companies report earning abroad are still booked in only a few low-tax havens — places that, of course, are not actually home to the customers, workers, and taxpayers facilitating most of their business. A multinational corporation can route its global sales

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ruled in 1957 that transactions executed by British banks on behalf of a lender and borrower who were not located in the UK, were not to be officially viewed as having taken place in the UK for regulatory or tax purposes, even though the transaction was only ever recorded as taking place in London.

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becomes State Secretary of Economic Affairs in May 2003 not long before the Wall Street Journal reports about his tour of the US, during which he pitches the new Netherlands tax policy to dozens of American tax lawyers, accountants, and corporate tax directors. In July 2005, he decides to abolish

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Academics who study tax havens, attribute Washington's support of U.S. corporate use of tax havens to a political compromise between Washington, and other higher-tax OECD nations, to compensate for shortcomings of the U.S. "worldwide" tax system. Hines had advocated for a switch to a "territorial"

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which used global national accounts data to calculate the quantum of net foreign asset positions of rich countries which are unreported because there are located in tax havens. Zucman estimated that circa 8–10% of the global financial wealth of households, or over US$ 7.6 trillion, was held in tax

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showed in 1994 that US corporations were achieving effective rates of taxation of circa 4% in corporate-focused OECD tax havens like Ireland. When in 2004, the US Congress stopped "naked tax inversions" by US corporations to Caribbean tax havens with the introduction of IRS Regulation 7874, a much

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projects) had been on common standards, transparency and data sharing. The rise of OECD-compliant corporate tax havens, whose BEPS tools were responsible for most of the lost taxes, led to criticism of this approach, versus actual taxes paid. Higher-tax jurisdictions, such as the United States and

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of taxes avoided vary, but the most credible have a range of US$ 100–250 billion per annum. In addition, capital held in tax havens can permanently leave the tax base (base erosion). Estimates of capital held in tax havens also vary: the most credible estimates are between US$ 7–10 trillion (up to

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The use of private 'unlimited liability company' (ULC) status, which exempts companies from filing financial reports publicly. The fact that Apple, Google and many others continue to keep their Irish financial information secret is due to a failure by the Irish government to implement the 2013 EU

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Preferential tax rulings (PTR) can be used by a jurisdiction for benign reasons, for example, tax incentives to encourage urban renewal. However, PTRs can also be used to provide aspects of tax regimes normally found in traditional tax havens. For example, while British citizens pay full taxes on

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We show theoretically and empirically that in the current international tax system, tax authorities of high-tax countries do not have incentives to combat profit shifting to tax havens. They instead focus their enforcement effort on relocating profits booked in other high-tax countries, in effect

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rankings, as their "headline" economic statistics are artificially inflated by the BEPS flows that add to the haven's GDP, but are not taxable in the haven. As the largest facilitators of BEPS flows, corporate-focused tax havens, in particular, make up most of the top 10-15 GDP-per-capita tables,

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Hines and Dharmapala concluded that governance was a major issue for smaller countries in trying to become tax havens. Only countries with strong governance and legislation which was trusted by foreign corporates and investors, would become tax havens. Hines and Dharmapala's positive view on the

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All havens are "captured" by offshore finance: local democracy mustn't be allowed to get in the way of making money. In 2014 the "big four" accountancy firms, key architects of the global offshore system, advertised in Hong Kong newspapers urging democracy demonstrators to pipe down, saying the

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It was certainly an improvement on the list recently published by the Organisation for Economic Co-operation and Development, which featured only one name – Trinidad & Tobago – but campaigners believe the European Union has much more to do if it is to prove it is serious about addressing tax

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In 2021 the G20 and OECD produced a report suggesting a change in how multinational enterprises (MNE) are taxed. Defining a MNE as a business with global turnover above 20 billion euros and profitability before tax above 10%. The object being to allocate the profit in excess of the 10% permitted

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who provided data on accounts held by over 100,000 clients and 20,000 offshore companies with HSBC in Geneva; the disclosure has been called "the biggest leak in Swiss banking history". Le Monde called upon 154 journalists affiliated with 47 different media outlets to process the data, including

5323:. CORPNET's Conduit OFCs contained several major jurisdictions considered OECD and/or EU tax havens, including the Netherlands, the United Kingdom, Switzerland, and Ireland. Conduit OFCs are strongly correlated with modern "corporate tax havens" and Sink OFCs with the "traditional tax havens". 3980:

is a country where the financial BEPS flows are out of proportion to the size of the indigenous economy. Apple's Q1 2015 "leprechaun economics" BEPS transaction in Ireland was a dramatic example, which caused Ireland to abandon its GDP and GNP metrics in February 2017, in favour of a new metric,

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U.S. companies are the most aggressive users of profit-shifting techniques, which often relocate paper profits without bringing jobs and wages, according to the study by economists Thomas Torslov and Ludvig Wier of the University of Copenhagen and Gabriel Zucman of the University of California,

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We identify 41 countries and regions as tax havens for the purposes of U. S. businesses. Together the seven tax havens with populations greater than one million (Hong Kong, Ireland, Liberia, Lebanon, Panama, Singapore, and Switzerland) account for 80 percent of total tax haven population and 89

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After losing 22 tax inversions from 2007 to 2010, mostly to Ireland, the UK decided to completely reform its corporate tax code. From 2009 to 2012 the UK reduced its headline corporate tax rate from 28% to 20% (and eventually to 19%), changed the British corporate tax code from a "worldwide tax

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In November 2014, the International Consortium of Investigative Journalists (ICIJ) released 28,000 documents totalling 4.4 gigabytes of confidential information about Luxembourg's confidential private tax rulings give to PricewaterhouseCoopers from 2002 to 2010 to the benefits of its clients in

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CONCLUSION: Using both bilateral and multilateral samples, we find empirically that successful offshore financial centers encourage bad behavior in source countries since they facilitate tax evasion and money laundering Nevertheless, offshore financial centers created to facilitate undesirable

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In 2007, the OECD estimated that capital held offshore amounted to between US$ 5 to 7 trillion, making up approximately 6–8% of total global investments under management. In 2017, as part of the OECD BEPS Project, it estimated that between US$ 100 to 240 billion in corporate profits where being

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The strongest consensus amongst academics regarding the world's largest tax havens is therefore: Ireland, Singapore, Switzerland and the Netherlands (the major Conduit OFCs), and the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Bermuda (the major Sink OFCs), with the United

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with other higher-tax jurisdictions. Instead, the receipts from investment structures in those jurisdictions are subject to full withholding tax set by the relevant onshore jurisdiction. The British Overseas Territories and Crown Dependencies all provide full tax transparency and automatic tax

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has criticised the list, stating that it has "no credibility", for failing to include various states of the USA which provide incorporation infrastructure which are indistinguishable from the aspects of pure tax havens to which the G20 object. As of 2012, 89 countries have implemented reforms

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global untaxed profits back to the haven (and on to Sink OFCs, as shown above). These "corporate tax havens" strongly deny any association with being a tax haven and maintain high levels of compliance and transparency, with many being OECD-whitelisted (and are OECD or EU members). Many of the

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corporate "profit shifting" (i.e. BEPS) is shielding over US$ 250 billion per year from taxes. Zucman's 2018 list of top 10 havens matched 9 of the top 10 havens in Hines' 2010 list, but with Ireland as the largest global haven. Zucman shows that US corporations are almost half of all profits

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For example, according to the UK Treasury, on the surface it looks like Britain's second-biggest investor is the Netherlands. But the UK Treasury has admitted most of those investments actually consist of British cash that has been sent to Holland for tax purposes and rerouted back home. So,

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Tax havens are low-tax jurisdictions that offer businesses and individuals opportunities for tax avoidance' (Hines, 2008). In this paper, I will use the expression 'tax haven' and 'offshore financial center' interchangeably (the list of tax havens considered by Dharmapala and Hines (2009) is

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showed that tax havens were typically small but well-governed nations and that being a tax haven had brought significant prosperity. In 2009, Hines and Dharmapala suggested that roughly 15% of countries are tax havens, but they wondered why more countries had not become tax havens given the

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Obviously many countries in the European Union are places where aggressive tax optimisation finds its place," Pierre Moscovici, the European commissioner for economic affairs and taxation, told reporters in Brussels yesterday. "Some European countries are black holes. . . I want to address

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Some authors on tax havens describe them as "captured states" by their offshore finance industry, suggesting the legal, taxation and other requirements of the professional service firms operating from the tax haven are given higher priority to any conflicting State needs. The term has been

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Lower foreign tax rates entail smaller credits for foreign taxes and greater ultimate U.S. tax collections (Hines and Rice, 1994). Dyreng and Lindsey (2009), offer evidence that U.S. firms with foreign affiliates in certain tax havens pay lower foreign taxes and higher U.S. taxes than do

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There have been many other "guesstimates" produced by NGOs which are either crude derivatives of the first method ("Banking data"), and are often criticised for taking mistaken interpretations and conclusions from aggregate global banking and financial data, to produce unsound estimates.

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It is the most cited paper on tax haven research, even in late 2017, and Hines is the most cited author on tax haven research. As well as offering insights into tax havens, it took the view that the diversity of countries that become tax havens was so great that detailed definitions were

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Stresses the importance of defending the freedom of journalists to report on issues of public interest without facing the threat of costly legal action, including when they receive confidential, secret or restricted documents, datasets or other materials, regardless of their origin.

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that almost half of these are U.S. corporations, and that it was the driver of how U.S. corporations built up offshore cash deposits of US$ 1 to 2 trillion since 2004. Zucman's (et alia) analysis showed that global GDP figures were materially distorted by multinational BEPS flows.

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Although a previous literature has modelled tax havens as a benign phenomenon that helps high-tax countries reduce the negative impact of their own suboptimal domestic tax policies, there is considerable concern that the havens are "parasitic" on the tax revenues of the non-haven

5074:

tax system, as most other nations use, which would remove U.S. multinational need for tax havens. In 2016, Hines, with German tax academics, showed that German multinationals make little use of tax havens because their tax regime, a "territorial" system, removes any need for it.

5985:

has adopted a specific list of jurisdictions deemed as tax havens by the Government, associated to said list are a set of tax penalties on Portuguese resident taxpayers. Nevertheless, the list has been critiqued for not being objective nor rational from an economic standpoint.

10557:

One of the criteria, for example, is that a country must be at least "largely compliant" with the Exchange Of Information on Request standard, a bilateral country-to-country information exchange. According to Turner, this standard is outdated and has been proven to not really

5102:

has noted that even where tax havens started out as "trading centres", they can eventually become "captured" by "powerful foreign finance and legal firms who write the laws of these countries which they then exploit". Tangible examples include the public disclosure in 2016 of

10146:

Although tax havens have attracted widespread interest (and a considerable amount of opprobrium) in recent years, there is no standard definition of what this term means. Typically, the term is applied to countries and territories that offer favorable tax regimes for foreign

12906:

Based on an analysis of data on tax disputes between tax authorities, the economists say that tax authorities in high-income countries tend to focus on transactions with other high-income countries rather than work on profit shifting trails that end in such island havens as

8539:

The eight major pass-through economies—the Netherlands, Luxembourg, Hong Kong SAR, the British Virgin Islands, Bermuda, the Cayman Islands, Ireland, and Singapore—host more than 85 percent of the world's investment in special purpose entities, which are often set up for tax

2194:, and unlike all past tax haven lists, were scaled quantitatively by analysing corporate investment flows. The Hines 2010 list was the first to estimate the ten largest global tax havens, only two of which, Jersey and the British Virgin Islands, were on the OECD's 2000 list. 8441:

Finally, we find that US firms with operations in some tax haven countries have higher federal tax rates on foreign income than other firms. This result suggests that in some cases, tax haven operations may increase US tax collections at the expense of foreign country tax

5807:

In April 2009 the OECD announced through its chief Angel Gurria that Costa Rica, Malaysia, the Philippines and Uruguay have been removed from the blacklist after they had made "a full commitment to exchange information to the OECD standards." Despite calls from the former

12994:

promote economic growth. Like many economists, Professor Hines expresses far more confidence in the market than in the state. He worries more about possible overtaxation than about undertaxation of corporate income. He does not engage with such concepts as "tax justice."

5612:

the "grey list" to the "black list" and vice-versa; stresses that this undermines the credibility, predictability and usefulness of the lists; calls for Parliament to be consulted in the preparation of the list and for an extensive revision of the screening criteria (§78)

5107:'s Project Goldcrest tax structure, which showed how closely the State of Luxembourg worked with Amazon for over two years to help it avoid global taxes. Other examples include how the Dutch Government removed provisions to prevent corporate tax avoidance by creating the 5402:

paid GBP£100,000 for the same data. The authorities in several other European countries, Australia and Canada also received the data. Liechtenstein's authorities strongly protested the case and issued an arrest order against the man suspected of having leaked the data.

4836:, showed that most corporate tax disputes are between high-tax jurisdictions, and not between high-tax and low-tax jurisdictions. Zucman (et alia) research showed that disputes with major havens such as Ireland, Luxembourg and the Netherlands, are actually quite rare. 1950:. However, in 1934, as a reaction to the global depression, the Swiss Banking Act of 1934 put bank secrecy under Swiss criminal law. Secrecy and privacy would become an important and distinctive part of the European-based tax havens, in comparison with other tax havens. 2432:

Thus, the evidence (limited though it undoubtedly is) does not suggest any impact of the OECD initiative on tax-haven activity. Thus, the OECD initiative cannot be expected to have much impact on corporate uses of tax havens, even if (or when) the initiative is fully

6030: 5310:

analysis of over 98 million global corporate connections. CORPNET ignored any prior definition of a tax haven or any legal or tax structuring concepts, to instead follow a purely quantitative approach. CORPNET's results split the understanding of tax havens into

3742:

Estimating the financial scale of tax havens is complicated by their inherent lack of transparency. Even jurisdictions that comply with OECD–transparency requirements such as Ireland, Luxembourg, and the Netherlands, provide alternate secrecy tools (e.g. Trusts,

3265:(United Kingdom dependency), still a major traditional tax haven; the CORPNET research identifies a very strong connection with Conduit OFC Switzerland (e.g. Switzerland is increasingly relying on Jersey as a traditional tax haven); issues of financial stability. 6114:

on the US corporate use of tax havens and the likely responses of US corporations to the TCJA. Since the TCJA, Pfizer has guided global aggregate tax rates that are very similar to what they expected in their aborted 2016 inversion with Allergan plc in Ireland.

3698:

in the 1990s and early 2000s severely damaged confidence in the country. The fact that the ship registration business still continues is partly a testament to its early success, and partly a testament to moving the national shipping registry to New York, United

7955:

With a conservatively estimated annual revenue loss of USD 100 to 240 billion, the stakes are high for governments around the world. The impact of BEPS on developing countries, as a percentage of tax revenues, is estimated to be even higher than in developed

13931:

As already noted, one of Luxembourg's key selling points for the world's mobile hot money has long been Luxembourg's role as a state 'captured' by offshore financial services, which has effectively removed the possibility of democratic opposition to the

5920:. In addition, the Commission produced a "greylist" of 47 jurisdictions which had already committed to cooperate with the EU to change their rules on tax transparency and cooperation. Only one of the EU's 17 blacklisted tax havens, namely Samoa, was in 1824:(due to accounting BEPS flows), havens are prone to over-leverage (international capital misprice the artificial debt-to-GDP). This can lead to severe credit cycles and/or property/banking crises when international capital flows are repriced. Ireland's 4946:("FDI") that came from tax havens into higher-tax countries, had really originated from the higher-tax country, and for example, that the largest source of FDI into the United Kingdom, was actually from the United Kingdom, but invested via tax havens. 3909:(FDI) was "phantom", and that "Empty corporate shells in tax havens undermine tax collection in advanced, emerging market, and developing economies". The research singled out Ireland, and estimated that over two-thirds of Ireland's FDI was "phantom". 4978:" rules, and U.S. hostility to OECD attempts in curbing Ireland's BEPS tools, and why, in spite of public disclosure of tax avoidance by firms such as Google, Facebook, and Apple, with Irish BEPS tools, little has been done by the U.S. to stop them. 12156:

James Henry, former chief economist at consultancy McKinsey and an expert on tax havens, has compiled the most detailed estimates yet of the size of the offshore economy in a new report, The Price of Offshore Revisited, released exclusively to the

15637:"Right now, it's safe to say that the U.K. is the preferred country of destination for inverted companies, given the favorable tax regime and the non-tax attractions of the U.K.," said Mr. Willens, a former managing director at Lehman Brothers. 13513:

Applying Hines and Rice's (1994) findings to a statutory corporate rate reduction of 15 percentage points (from 35 to 20 percent) suggests that reduced profit shifting would result in more than $ 140 billion of repatriated profit based on 2016

10332:

8852: 2779:

tables – Another "sense–check" of a tax haven is distortion in its GDP data from the IP–based BEPS tools and Debt–based BEPS tools. Excluding the non-oil & gas nations (e.g. Qatar, Norway), and micro jurisdictions, the resulting highest

2243:

produces its first formal list of tax havens with 17 countries on its 2017 blacklist and 47 on its 2017 greylist; however, as with the previous 2010 OECD list, none of the jurisdictions are OECD or EU–28 countries, nor are they in the list of

2308:

The issue, however, is material, as being labelled a "tax haven" has consequences for a country seeking to develop and trade under bilateral tax treaties. When Ireland was "blacklisted" by G20 member Brazil in 2016, bilateral trade declined.

12347:

Mr Henry said his $ 21tn is actually a conservative figure and the true scale could be $ 32tn. A trillion is 1,000 billion. Mr Henry used data from the Bank of International Settlements, International Monetary Fund, World Bank, and national

4970:. Hines showed that as a result of paying no foreign taxes by using tax havens, U.S. multinationals avoided building up foreign tax credits that would reduce their U.S. tax liability. Hines returned to this finding several times, and in his 2427:

investigation into tax havens, as being restrictive, and enabling Hines' low-tax havens (e.g. to which the first criterion applies), to avoid the OECD definition by improving OECD cooperation (so the second and third criteria do not apply).

5098:

particularly used for smaller tax havens, with examples being Delaware, the Seychelles, and Jersey. However, the term "captured state" has also been used for larger and more established OECD and EU offshore financial centres or tax havens.

2615:

post–World War II. Since the reform of its corporate tax code in 2009–2012, the UK has re-emerged as a major corporate-focused tax haven. Two of the five major global Conduit OFCs are from this grouping (e.g. the U.K. and Singapore).

11355: 2130:; none of the existing 35 OECD members, or EU–28 members, were listed as tax havens. By 2008, only Trinidad & Tobago met the OECD's Criteria to be a tax haven. Academics start using the terms "OECD tax havens" and "EU tax havens". 13076: 10271: 6420:

The ITEP list only focuses on Fortune 500 Companies; its strong correlation with tax haven lists derived from global studies highlights that U.S multinationals are the most dominant source of global tax avoidance, and users of tax

4949:

The boundaries with wider contested economic theories on the effects of corporate taxation on economic growth, and whether there should be corporate taxes, are easy to blur. Other researchers that have examined tax havens, such as

9838: 5271:

for IP law (see graphic). These "corporate tax havens" (or Conduit OFCs), further increase respectability by requiring the corporate using their BEPS tools/PTRs to maintain a "substantial presence" in the haven; this is called an

1796:("BEPS") tools enable corporates to achieve "effective" tax rates closer to zero, not just in the haven but in all countries with which the haven has tax treaties; putting them on tax haven lists. According to modern studies, the 14320:

ANDREA KELLY (PwC Ireland): "We expect most Irish QIAIFs to be structured as ICAVs from now on and given that ICAVs are superior tax management vehicles to the Cayman Island SPCs, Ireland should attract substantial re-domiciling

5617:

notes that despite the implementation of European and national legislation on beneficial ownership transparency, as reported by non-governmental organisations, the quality of data in some EU public registers requires improvement

5359:

is a structure used by asset managers as it can accommodate asset classes such as intellectual property ("IP") assets, cryptocurrency assets, and carbon credit assets; competitor products include the Irish QIAIF and Luxembourg's

9286:

said: It's disheartening to see the OECD fall back into the old pattern of creating 'tax haven' blacklists on the basis of criteria that are so weak as to be near enough meaningless, and then declaring success when the list is

5594:(ICIJ). The leak exposed the secret offshore accounts of 35 world leaders, including current and former presidents, prime ministers, and heads of state as well as more than 100 billionaires, celebrities, and business leaders. 5517:

In 2015, 11.5 million documents totalling 2.6 terabytes, detailing financial and attorney-client information for more than 214,488 offshore entities, some dating back to the 1970s, that were taken from the Panamanian law firm

6089:

showed that many of the outstanding British inversions from 2007 to 2010 period had returned to the UK as a result of the tax reforms (most of the rest had entered into subsequent transactions and could not return, including

4814:

are represented above (Ireland, Singapore, Switzerland, the Netherlands, Luxembourg and Hong Kong), and the remaining 3 havens (Cayman Islands, Bermuda, British Virgin Islands), do not appear in World Bank-IMF GDP-per-capita

9509:

The 17 countries on the European list are American Samoa, Bahrain, Barbados, Grenada, Guam, South Korea, Macau, the Marshall Islands, Mongolia, Namibia, Palau, Panama, St Lucia, Samoa, Trinidad & Tobago, Tunisia and the

3717:'s Financial Services commissioner said in May 2008 that his country would reform laws and cease being a tax haven. "We've been associated with this stigma for a long time and we now aim to get away from being a tax haven." 3993: 8095:

The equivalent of 10% of global GDP is held offshore by rich individuals in the form of bank deposits, equities, bonds and mutual fund shares, most of the time in the name of faceless shell corporations, foundations and

12758: 11785: 5734:

for tax havens, to be segmented according to a four-tier system, based on compliance with an "internationally agreed tax standard". The list as per 2 April 2009 can be viewed on the OECD website. The four tiers were:

8487:

As a result of the Bush Administration's efforts, the OECD backed away from its efforts to target "harmful tax practices" and shifted the scope of its efforts to improving exchanges of tax information between member

2606:

lists, namely: Caribbean tax havens (e.g., Bermuda, the British Virgin Islands, and the Cayman Islands), Channel Islands tax havens (e.g. Jersey) and Asian tax havens (e.g., Singapore and Hong Kong). As discussed in

12311:

The study estimating the extent of global private financial wealth held in offshore accounts - excluding non-financial assets such as real estate, gold, yachts and racehorses - puts the sum at between $ 21 and $ 32

11407: 10601:

Ireland does not meet any of the OECD criteria for being a tax haven but because of its 12.5 per cent corporation tax rate and the open nature of the Irish economy, Ireland has on a few occasions been labeled a tax

6160: 1000: 5275:, and can cost the corporate circa 2–3% of revenues. However, these initiatives enable the corporate tax haven to maintain large networks of full bilateral tax treaties, that allow corporates based in the haven to 13988: 12664:

One recent report said that the bulk of the foreign direct investment here was "phantom" and driven by tax avoidance. Another said that we are one of the world's biggest tax havens. More leprechaun economics at

11526: 9587:

EU members were not screened but Oxfam said that if the criteria were applied to publicly available information the list should feature 35 countries including EU members Ireland, Luxembourg, the Netherlands and

7448:

Local subsidiaries of multinationals must always be required to file their accounts on public record, which is not the case at present. Ireland is not just a tax haven at present, it is also a corporate secrecy

1991:. As well as the dramatic rise in OFCs, from the late 1960s onwards, new tax havens began to emerge to service developing and emerging markets, which became Palan's third group. The first Pacific tax haven was 15560:

So, if you think about a lot of technology companies that are housed in Ireland and have massive operations there, they're not going to maybe need those in the same way, and those can be relocated back to the

5394:, a Liechtenstein bank, for a list of 1,250 customer account details of the bank. Investigations and arrests followed relating to charges of illegal tax evasion. The German authorities shared the data with US 1738:" are almost synonymous. In reality, many offshore financial centers do not have harmful tax practices and are at the forefront among financial centers regarding AML practices and international tax reporting. 14474: 14344: 12117:(From abstract) In this paper we argue that such claims rest on poor data and analysis, and on mistakes about how financial transactions, international taxation, and anti-money laundering rules actually work. 3585:(Δ) Identified on the first, and the largest, OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017); the above list contains 34 of the 35 (U.S. Virgin Islands missing). 2060:

noted the creation of such "non-resident" companies was "a loophole which, in a sense, made Britain a tax haven". The ruling applied to the British Empire, including Bermuda, Barbados, and the Cayman Islands.

1940:

14096: 5013:

global profits shifted to tax havens are shifted by U.S. multinationals. By contrast, about 25% accrues to E.U. countries, 10% to the rest of the OECD, and 15% to developing countries (Tørsløv et al., 2018).

2536:), and "enhanced corporate profitability" that Hines and Dharmapala had noted. Zucman pointed out that the CORPNET research under-represented havens associated with US technology firms, like Ireland and the 2183:("FSI") and the term "secrecy jurisdiction", to highlight issues in regard to OECD-compliant countries who have high tax rates and do not appear on academic lists of tax havens, but have transparency issues. 13534: 14109:

EU State Aid Rules and the investigation into preferential tax ruling involving Apple Inc. will be on the agenda when the Committee on Finance, Public Expenditure and Reform, and Taoiseach meets tomorrow

11811: 11266: 5339:(SPCs). These SPVs and SPCs are not only free of all taxes, duties, and VAT, but are tailored to the regulatory requirements, and the banking requirements of specific segments. For example, the zero-tax 1964:(OFCs). Many of these OFCs were traditional tax havens from the Post World War I phase, including the Cayman Islands and Bermuda, however new centres such as Hong Kong and Singapore began to emerge. The 15260: 11236: 11133: 10167: 9797: 9769:'Ireland solidifies its position as the #1 tax haven,' Zucman said on Twitter. 'U.S. firms book more profits in Ireland than in China, Japan, Germany, France & Mexico combined. Irish tax rate: 5.7%.' 7860: 15677:

In 2007 to 2009, WPP, United Business Media, Henderson Group, Shire, Informa, Regus, Charter and Brit Insurance all left the UK. By 2015, WPP, UBM, Henderson Group, Informa and Brit Insurance have all

8174:

23.Nauru 24.Net Antilles 25.Niue 26.Panama 27.Samoa 28.Seychelles 29.St. Lucia 30.St. Kitts & Nevis 31.St. Vincent and the Grenadines 32.Tonga 33.Turks & Caicos 34.U.S. Virgin Islands 35.Vanuatu

13768: 10455: 9756: 6353:

The FSI is often misquoted as a ranking of "tax havens", however the FSI does not quantify tax avoidance or BEPS flows like modern quantitative tax haven lists; the FSI it is a qualitative scoring of

8526: 3089:

In a June 2018 joint IMF report into the effect of BEPS flows on global economic data, eight of the above (excluding Switzerland and the United Kingdom) were cited as the world's leading tax havens.

10544: 15108: 9950:

The Republic helps big multinationals to engage in aggressive tax planning and the European Commission should regard it as one of five "EU tax havens" until substantial tax reforms are implemented.

7500:

Various attempts have been made to identify and list tax havens and offshore finance centres (OFCs). This Briefing Paper aims to compare these lists and clarify the criteria used in preparing them.

2375: 3860:(a lobby group for the financial services sector in Jersey), and written by two U.S. academics, Richard Morriss and Andrew Gordon. In 2014, the TJN issued a report responding to these criticisms. 15476: 14070: 1880:, New Jersey and Delaware were successful, and though not explicitly tax havens (e.g. US federal and state taxes applied), many future tax havens would copy their "liberal" incorporation regimes. 10768:

It focuses particularly on the dominant approach within the economics literature on income shifting, which dates back to Hines and Rice (1994) and which we refer to as the "Hines-Rice" approach.

3949:

financial benefits of becoming a tax haven, as well as being two of the major academic leaders into tax haven research, put them in sharp conflict with non-governmental organisations advocating

16546: 15755: 12288: 8839:

The OECD is clearly ill-equipped to deal with tax havens, not least as many of its members, including the UK, Switzerland, Ireland and the Benelux countries are themselves considered tax havens

6361:, the trust, and various special purpose vehicles (e.g. Irish QIAIFs and L–QIAIFs)—few of which are required to file public accounts in major tax havens, such as Ireland and the United Kingdom. 15412: 14672: 13605:

John Christensen and Mark Hampton (1999) have shown how several tax havens have in effect been "captured" by these private interests, which literally draft local laws to suit their interests.

11347: 1865:

While areas of low taxation are recorded in Ancient Greece, tax academics identify what we know as tax havens as being a modern phenomenon, and note the following phases in their development:

13072: 10267: 9867: 7799: 7770: 3389:

study that were not considered havens in 2010, namely the United Kingdom, Taiwan, and Curaçao. The James Hines 2010 list contains 34 of the original 35 OECD tax havens; and compared with the

11745: 9904: 9231: 7415:

Accounting Directive, which would require full public financial statements, until 2017, and even then retaining an exemption from financial reporting for certain holding companies until 2022

15165: 14771: 13628: 10927: 1902:. However, most tax academics identify the Zurich-Zug-Liechtenstein triangle as the first "tax haven hub" created during the mid-1920s. Liechtenstein's 1924 Civil Code created the infamous 14021: 12449: 11210: 11065: 10791: 7435: 6408:

Ireland is also connected to the British Empire–related tax havens as Ireland's common law legal system, and company tax system, are more derived from the UK, then from Continental Europe.

6017:, which culminated with the effective block of the proposed 2016 US$ 160 billion of Pfizer-Allergan in Ireland. Since these changes, there have been no further material US tax inversions. 5967:

to "display traits of a tax haven and facilitate aggressive tax planning". However, despite this vote, the EU Commission is not obliged to include these EU jurisdictions on the blacklist.

2671:

Governmental, Qualitative: these lists are qualitative and political; they never list members (or each other), and are largely disregarded by academic research; the EU had 16 countries on

11469: 11381: 9828: 5667:(FATCA), which requires foreign financial institutions (FFI) of broad scope – banks, stock brokers, hedge funds, pension funds, insurance companies, trusts – to report directly to the US 4905:("OFCs"), a closely related term to tax havens, noted the positive and negative aspects of OFCs on neighbouring high-tax, or source, economies, and marginally came out in favour of OFCs. 16373: 13284: 12531:

US companies are by far the biggest users of tax havens, where they face effective tax rates of just seven percent, according to the study by economists Thomas Wright and Gabriel Zucman.

2723: 14606: 14204: 13327: 7173:

A tax haven is a country or place which has a low rate of tax so that people choose to live there or register companies there in order to avoid paying higher tax in their own countries.

4873:

The effect of tax havens on economic welfare in high tax countries is unclear, though the availability of tax havens appears to stimulate economic activity in nearby high-tax countries.

13258: 10865: 8082: 2627:(Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Turks and Caicos Islands), "to identify the opportunities and challenges as offshore financial centres", for the 8333:

ABSTRACT: Per capita real GDP in tax haven countries grew at an average annual rate of 3.3 percent between 1982 and 1999, which compares favorably to the world average of 1.4 percent.

13882: 13493: 10312: 9535: 5470:, was given over 3.3 gigabytes of confidential client data relating to a tax evasion scheme allegedly operated with the knowledge and encouragement of the British multinational bank 2854: 2746: 1813:

10% of global assets). The harm of traditional and corporate tax havens has been particularly noted in developing nations, where the tax revenues are needed to build infrastructure.

14639: 1936:

in Britain created the "non-resident corporation" and recognised a British-registered company with no business activities in Britain is not liable to British taxation. Tax academic

8959: 7709: 7684: 7659: 12375: 7734: 7634: 7591: 6314:

Many corporate–focused tax havens have high nominal rates of taxation (e.g. Netherlands at 25%, United Kingdom at 19%, Singapore at 17%, and Ireland at 12.5%), but maintain a tax

15303:

The move brought the list down to five non-cooperative jurisdictions - Samoa, Trinidad and Tobago and the three US territories of American Samoa, Guam, and the US Virgin Islands.

11697: 8717: 4841:

stealing revenue from each other. This policy failure can explain the persistence of profit shifting to low-tax countries despite the high costs involved for high-tax countries.

2419:(†) The 4th criterion was withdrawn after objections from the new U.S. Bush Administration in 2001, and in the OECD's 2002 report the definition became "two of three criteria". 10755: 6045:

The Double Irish was the largest BEPS tool in history which by 2015, was shielding over US$ 100 billion in mostly US corporate profits from US taxation. When the EU Commission

3124:(Δ) Identified on the largest OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017); only four locations below were ever on an OECD list. 12750: 11496: 10528:

The four OECD member countries Luxembourg, Ireland, Belgium, and Switzerland, which can also be regarded as tax havens for multinationals because of their special tax regimes.

1816:

Over 15% of countries are sometimes labelled tax havens. Tax havens are mostly successful and well-governed economies, and being a haven has brought prosperity. The top 10–15

14705: 13732: 11781: 8741:"he tax haven is a creature of the twentieth century, and began to be used extensively because of the high levels of tax which prevailed after the First World War" at ¶26.1, 8600: 3972:

excluding oil and gas nations (see table below). Research into tax havens suggest a high GDP-per-capita score, in the absence of material natural resources, as an important

2802:'s June 2018 study also appear in the top ten lists of the two other quantitative studies since 2010. Four of the top five Conduit OFCs are represented; however, the UK only 8207: 7825: 3962: 3083: 2781: 11836: 11585: 11403: 6009:

of US corporations to mostly Caribbean-type tax havens (e.g. Bermuda and the Cayman Islands), the US Congress added Regulation 7874 to the IRS code with the passing of the

9000: 7939: 6923: 2602:

Many tax havens are former or current dependencies of the United Kingdom and still use the same core legal structures. Six British Empire–related tax havens appear in the

1981:

The rise of OFCs would continue so that by 2008, the Cayman Islands would be the 4th largest financial centre in the world, while Singapore and Hong Kong had become major

15191: 2005:

on the use of tax havens by US taxpayers, which highlighted the use by tax havens by US corporations. In 1983, US corporation McDermott International executed the first

15521:

TWO YEARS AFTER the controversial 'double Irish' loophole was closed to new entrants, Google continued using the system to funnel billions in untaxed profits to Bermuda.

13980: 13665: 12230: 12187: 11518: 10896: 7401: 6399:

to formally include these "EU tax havens" in the official EU list of tax havens (blacklist or greylist); to be binding, it must be a unanimous vote by all member states.

4954:, highlight the injustice of tax havens and see the effects as lost income for the development of society. It remains a controversial area with advocates on both sides. 3931:

There are roughly 40 major tax havens in the world today, but the sizable apparent economic returns to becoming a tax haven raise the question of why there are not more.

3036:

Ireland, Singapore, Switzerland and the Netherlands (the Conduit OFCs), and the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Bermuda (the Sink OFCs)

2232:. CORPNET's lists of top five Conduit OFCs and top five Sink OFCs, matched 9 of the top 10 havens in Hines' 2010 list, only differing in the United Kingdom, which only 15323: 15017: 14738: 10512: 10193: 10074: 3105:

study, at 29 (5 Conduit OFCs and 25 Sink OFCs). The following are the 20 largest (5 Conduit OFCs and 15 Sink OFCs), which reconcile with other main lists as follows:

10378:

Concerning the characterization of tax havens, we follow the definition proposed by Hines and Rice (1994) which has been recently used by Dharmapala and Hines (2009).

14466: 14334: 13223: 12792: 12485: 12412: 5372:

Some businesses in tax havens have been subject to the illegal obtaining and either public or non-public disclosures of client account data, the most notable being:

5047:

through Ireland, pay royalties to its Dutch subsidiary and then funnel income to its Bermudian subsidiary — taking advantage of Bermuda's corporate tax rate of zero.

14092: 13806: 13454: 13414: 12029: 9994:"INTERNATIONAL TAXATION: Large U.S. Corporations and Federal Contractors with Subsidiaries in Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions" 9134: 7342: 16668: 15223: 10971: 9374: 8398:

Jersey bet its future on finance but since 2007 it has fallen on hard times and is heading for bankruptcy. Is the island's perilous present Britain's bleak future?

3137:– a major corporate tax haven, and ranked by some tax academics as the largest; leader in IP–based BEPS tools (e.g. double Irish), but also Debt-based BEPS tools. 2570:

While tax havens are diverse and varied, tax academics sometimes recognise three major "groupings" of tax havens when discussing the history of their development:

1968:

was an extreme case of tax leniency and banking secrecy in the period following its wartime suspension, but that was brought to an end in 1960 as a consequence of

13526: 11078:

We've criticised for years the farcical nature of 'tax haven' blacklists, whether EU or OECD ones. They all turn out to be politicised, misleading and ineffective

11807: 11325: 11258: 10585: 8108: 6947: 5207:) its untaxed profits to the new tax haven. These are called base erosion and profit shifting (BEPS) techniques. Notable BEPS tools like the Double Irish with a 2330:

inappropriate. Hines merely noted that tax havens were: "a group of countries with unusually low tax rates". Hines reaffirmed this approach in a 2009 paper with

15250: 14241: 13819:

But on another level this is an Irish version of a phenomenon we've encountered across the tax haven world: the state 'captured' by offshore financial services.

12143: 11232: 11125: 10159: 9787: 7852: 5262:

Traditional OFCs, such as Cayman, BVI, Guernsey or Jersey are clear about their corporate tax neutrality. Because of this, they tend not to sign full bilateral

16607: 15056: 11856:

Reuven S. Avi-Yonah (2012): Statement to Congress; University of Michigan School of Law, Permanent Subcommittee on Investigations, U.S. Congress, 20 Sep. 2012.

10422: 5823:

to be included on the list separately from China, they are as yet not included independently, although it is expected that they will be added at a later date.

11983: 8317: 16465: 16424: 14507: 14470: 13758: 12068: 10448: 9900: 9746: 7004: 5591: 5418: 2688:

Non-governmental, Quantitative: by following an objective quantitative approach, they can rank the relative scale of individual havens; the best known are:

2493:'s CORPNET group ignored any definition of a tax haven and focused on a purely quantitive approach, analysing 98 million global corporate connections on the 15624: 14573: 13014: 12685: 8514: 8417:"Using Financial Accounting Data to Examine the Effect of Foreign Operations Located in Tax Havens and Other Countries on US Multinational Firms' Tax Rates" 2390:

has never listed any of its 35 members as tax havens, Ireland, Luxembourg, the Netherlands, and Switzerland are sometimes defined as the "OECD tax havens".

16406: 15799:

Examples of such tax havens include Ireland and Luxembourg in Europe, Hong Kong and Singapore in Asia, and various Caribbean island nations in the Americas

14270: 13957: 11615: 10540: 7277: 15547: 15100: 14540: 14377: 12980: 12822: 11870: 8360: 3841:

USD 21 to 32 trillion of global assets (over 20% of global wealth) "has been invested virtually tax-free in more than 80 offshore secrecy jurisdictions";

3713:

Some Pacific islands were tax havens but were curtailed by OECD demands for regulation and transparency in the late 1990s, on the threat of blacklisting.

2213:

to Ireland (called leprechaun economics); by 2016, the US Treasury tighten the inversion rules, causing Pfizer to abort their US$ 160 billion merger with

15472: 15353: 15080: 14847:"For most individual taxpayers, this means they will start filing Form 8938 with their 2011 income tax return to be filed this coming tax filing season." 13835: 9971: 7484: 14062: 12870: 8826: 8655: 17803: 9880:

Members of the European Parliament have voted to include the Netherlands, Ireland, Luxembourg, Malta and Cyprus on the official EU tax haven blacklist.

6046: 5230:

profits between jurisdictions. The concept of a corporation charging its costs from one jurisdiction against its profits in another jurisdiction (i.e.

5154: 3752: 15661: 14410: 11948: 15404: 14857: 14662: 14133: 7480: 5429:; Mongolia's finance minister, Bayartsogt Sangajav; the president of Azerbaijan; the wife of Russia's Deputy Prime Minister; and Canadian politician 1985:(RFCs). By 2010, tax activists would promote the notion that OFCs are synonymous with tax havens, and that most of their services involved taxation. 15699: 9863: 7795: 7762: 4888:

have exhibited more rapid real income growth than have those further away, possibly in part as a result of financial flows and their market effects.

18429: 15290: 13618: 12731:

First, many these claims rest heavily on work done by James Hines of the University of Michigan and a few others – research that is fatally flawed.

11737: 11638: 9896: 9223: 4000:

called the 2015 restatement of Ireland's national accounts, as a result of the Q1 2015 restructuring of Apple's BEPS tools, "leprechaun economics".

3706:

had a short existence as a tax haven in the period between the end of effective control by the Spanish in 1945 until it was formally reunited with

15161: 14761: 14443: 13782:

protests would scare away their financial and multinational clients, with "a long-term impact on Hong Kong's status as a global financial centre".

12438: 10919: 2619:

In November 2009, Michael Foot, a former Bank of England official and Bahamas bank inspector, delivered an integrated report on the three British

15588: 14909: 14011: 12518: 11202: 11057: 10783: 7427: 2821:. In Q1 2015, Apple completed the largest BEPS action in history, when it shifted US$ 300 billion of IP to Ireland, which Nobel-prize economist 2598:

British Overseas Territories (same geographic scale) includes leading traditional and corporate tax global tax havens, including the U.K. itself.

1841: 12849: 12595: 11461: 11377: 9190: 16442: 15508: 13280: 11923: 11901: 14596: 13317: 3604:), a unique "onshore" specialised haven with strong secrecy laws and a liberal incorporation regime; however Federal and State tax apply (see 3257:

Sovereign or sub-national states that are very traditional tax havens (i.e. explicit 0% rate of tax) include (fuller list in table opposite):

2517:

24 Sink OFCs: jurisdictions in which a disproportionate amount of value disappears from the economic system (e.g. the traditional tax havens).

16575: 15445: 14208: 13250: 10857: 9574: 9496: 9269: 8072: 2520:

5 Conduit OFCs: jurisdictions through which a disproportionate amount of value moves toward sink OFCs (e.g. the modern corporate tax havens).

1346: 12618: 10625: 7160: 17660: 16678: 16658: 14629: 13872: 13480: 12298: 10713: 10299: 9527: 7196: 6029:, it was agreed that the OECD undertake a project to combat base erosion and profit shifting (BEPS) activities by corporates. An OECD BEPS 5631:

Transparency. Actions that promote visibility into the entities operating within the tax haven, and including data and information sharing.

4942:

campaign groups have been equally critical of Hines, and others, in these views. Research in June 2018 by the IMF showed that much of the

2798:

notes that as corporate BEPS flows dominate tax haven activity, these are mostly corporate tax havens. Nine of the top ten tax havens in

1722:. However, while countries with high levels of secrecy but also high rates of taxation, most notably the United States and Germany in the 16716: 16551: 16395: 13183: 12364: 9310: 8951: 8043: 6053:) were already operating. The lack of action by the US, similar to their position with the OECD MLI (above), has been attributed to the 5634:

Blacklists. A coercive tool used by both the OECD and the EU to encourage cooperation by tax havens with their transparency initiatives.

5179:" is where the corporate had little prior business activities in the new location. The first tax inversion was the "naked inversion" of 3847:

USD 7.3 to 9.3 trillion is represented by individuals from a subset of 139 "low to middle income" countries for which data is available;

3052:(Δ) Identified on the first, and largest, OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017). 1848:("TCJA") GILTI–BEAT–FDII tax regimes and move to a hybrid "territorial" tax system, and proposed EU Digital Services Tax regime, and EU 18342: 17876: 16563: 16459: 15712:

While lawmakers generally refer to the new system as a "territorial" tax system, it is more appropriately described as a hybrid system.

11719: 11689: 11180: 8694: 6896: 4910:

activities can still have unintended positive consequences. We tentatively conclude that OFCs are better characterized as "symbionts".

2794:

The post-2010 rise in quantitative techniques of identifying tax havens has resulted in a more stable list of the largest tax havens.

2612: 14826: 13915: 10232: 7579:

identical to the list of offshore financial centers considered by the Financial Stability Forum (IMF, 2000), barring minor exceptions)

5640:

Fundamental. Where the higher-tax jurisdictions conduct a reform of their taxation systems to remove the incentives to use tax havens.

5331:

As well as corporate structures, tax havens also provide tax-free (or "tax neutral") legal wrappers for holding assets, also known as

5211:

were used by US corporations to build up untaxed offshore cash reserves of US$ 1–2 trillion in tax havens like Bermuda (e.g., Apple's

3684:

crash of 1966, and the subsequent political and military deterioration of Lebanon dissuaded foreign use of the country as a tax haven.

1844:

in 2017–18 to introduce anti-BEPS tax regimes, targeted raising net taxes paid by corporations in corporate tax havens (e.g. the U.S.

17665: 14879: 11105: 10747: 7616: 6331:

Since the post–2000 OECD–IMF–FATF initiatives on reducing banking secrecy and increasing transparency, modern academics consider the

6033:, consisting of "15 Actions" designed to be implemented domestically and through bilateral tax treaty provisions, were agreed at the 5183:

to Panama in 1983. The US Congress effectively banned "naked inversions" for US corporates by introducing IRS regulation 7874 in the

4800: 4023: 4012: 3968: 3345: 2776: 2656: 1817: 1203: 14304: 11492: 11146:

The new research draws on data from countries such as Ireland, Luxembourg and the Netherlands that hadn't previously been collected.

10133: 10038: 8911: 3905:

the same team published further research titled, "The Rise of Phantom Investments", that estimated that a high percentage of global

3330:– the Dutch dependency ranked 8th on the Oxfam's tax haven list, and the 12th largest Sink OFC, and recently made the EU's greylist. 17637: 16493: 14695: 13724: 8592: 8250: 6180: 6128:

between all nations where the MNE derived turnover. The report had been agreed by 139 OECD member jurisdictions as of 9 June 2023.

1068: 1063: 14932:"A Progress Report on The Jurisdictions Surveyed by The OECD Global Forum in Implementing The Internationally Agreed Tax Standard" 7821: 7137:

A country with little or no taxation that offers foreign individuals or corporations residency so that they can avoid tax at home.

504: 16773: 16535: 16400: 12099:

Gordon, Richard; Morriss, Andrew (20 October 2013). "Moving Money: International Financial Flows, Taxes & Money Laundering".

11833: 11581: 10362: 10070: 9710: 5627:

The various countermeasures that higher-tax jurisdictions have taken against tax havens can be grouped into the following types:

2809:

The studies capture the rise of Ireland and Singapore, both major regional headquarters for some of the largest BEPS tool users,

9081: 7928: 6013:. Although the legislation was effective, further US Treasury regulations were required in 2014–2016 to prevent the much larger 2289:

There is no established consensus regarding a specific definition for what constitutes a tax haven. This is the conclusion from

17808: 17798: 16793: 16623: 16540: 15733: 15187: 13698: 13445: 12176: 10661: 10581: 7562: 7317: 2450:(or FSF) defined the related concept of an offshore financial centre (or OFC), which the IMF adopted in June 2000, producing a 2359: 2271:

votes to accept a report by 505 votes in favour to 63 against, identifying five "EU tax havens" that should be included on the

1849: 1741:

Developments over the past decade have substantially reduced the ability for individuals or corporations to use tax havens for

1417: 1010: 231: 15870: 13657: 12219: 10888: 10828: 7898: 7393: 5554:

In 2017, 13.4 million documents totalling 1.4 terabytes, detailing both personal and major corporate client activities of the

1886:. The modern concept of a tax haven is generally accepted to have emerged at an uncertain point in the immediate aftermath of 1757:

by most countries, including typical tax havens, a multilateral automatic taxpayer data exchange agreement, initiative of the

499: 18251: 18043: 16487: 16429: 16358: 14994: 14963: 14728: 13598: 9010: 7071: 7052: 6994: 6933: 6882: 5827: 3644:

Neither the U.S. nor Germany have appeared on any tax haven lists by the main academic leaders in tax haven research, namely

15315: 15025: 12058:"COMMISSION DECISION of 30.8.2016 on STATE AID SA. 38373 (2014/C) (ex 2014/NN) (ex 2014/CP) implemented by Ireland to Apple" 11559: 10481: 10189: 10063: 8471: 7022: 5153:

disclosure revealed 548 PTRs issued by the Luxembourg authorities to corporate clients of PriceWaterhouseCoopers. When the

5081:("CEA") in drafting the TCJA legislation in 2017, and advocating for moving to a hybrid "territorial" tax system framework. 3086:, and of the four others, three of them, the Caribbean locations, are not included in IMF-World Bank GDP-per-capita tables. 18048: 17768: 17758: 17136: 16706: 16701: 16482: 16412: 15943: 12930: 11437: 10824: 10397: 9706: 9617: 8569: 5120:

the provision that was meant to prevent tax dodging by American companies, in order to meet criticism from tax consultants.

5022: 3294:, largest Sink OFC in the world and regularly appears alongside the Caymans and Bermuda (the Caribbean "triad") as a group. 2830: 1617: 798: 15909: 13394: 13213: 12784: 12475: 12404: 12334: 12018: 6480:

The following are the most cited papers on "tax havens", as ranked on the IDEAS/RePEc database of economic papers, at the

6374:

numbered 206 as at September 2018, so 15% equates to just over 30 tax havens; the OECD's 2000 list had 35 tax havens, the

2532:) published research that also ignored any definition of a tax haven, but estimated the corporate "profit shifting" (i.e. 18210: 17670: 17141: 16628: 16523: 16517: 14237: 14171: 13798: 13440: 9123: 8389: 8157: 7312: 5680: 5251: 5008:

Research in June–September 2018, confirmed U.S. multinationals as the largest global users of tax havens and BEPS tools.

3177:

Sovereign states or autonomous regions that feature as both major corporate tax havens and major traditional tax havens:

3144:– the major corporate tax haven for Asia (APAC headquarters for most US technology firms), and key conduit to core Asian 3126:(↕) Identified on the European Union's first 2017 list of 17 tax havens; only one location below is on the EU 2017 list. 2424: 2302: 1492: 15213: 12265: 11126:"Zucman:Corporations Push Profits Into Corporate Tax Havens as Countries Struggle in Pursuit, Gabrial Zucman Study Says" 10950: 9366: 8254: 7853:"Zucman:Corporations Push Profits Into Corporate Tax Havens as Countries Struggle in Pursuit, Gabrial Zucman Study Says" 7293:

The 'tax havens' are locations with very low tax rates and other tax attributes designed to appeal to foreign investors.

7010: 5637:

Specific. Sets of legislative and/or regulatory actions targeted at specifically identified issues regarding tax havens.

2471: 2158: 18033: 17482: 17382: 16353: 15899: 15891:"Profiting from Corruption: The Role and Responsibility of Financial Institutions" – U4 Anti-Corruption Resource Centre 15139: 13852: 13408: 12718: 10570: 10090:

There is no single definition of a tax haven, although there are a number of commonalities in the various concepts used

10004: 9829:"New research finds 40% of multinationals' profits shifted to tax havens – EU biggest loser while US firms most shifty" 8711: 7535: 7124: 6957: 6909: 6852: 6824: 6010: 5843: 5684: 5664: 5658: 5184: 3779: 2672: 2451: 2165: 2146: 2071:

by Richard A. Gordon Special Counsel for International Taxation at the IRS. The Gordon Report identifies new types of

1750: 1694: 1557: 680: 192: 14230: 13361: 11321: 9621: 18231: 17235: 17126: 16987: 16529: 16453: 15366:

Ireland has been likened to a tax haven in a new report which was overwhelmingly accepted by the European Parliament.

13566: 12133: 10965: 10707: 10020:

Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions and the Sources of Those Jurisdictions

9048: 8770: 8750: 7016: 6481: 5537: 5238:

of all global profits back to the tax haven. IP has been described as "the leading corporate tax avoidance vehicle".

2806:

in 2009–2012. All five of the top 5 Sink OFCs are represented, although Jersey only appears in the Hines 2010 list.

1018: 766: 15048: 10997: 10426: 7028: 5475: 3800:

flows of multinationals that are untaxed; associated with tax academics (Hines, Zucman), NGOs, and OECD–IMF studies.

3324:– has become a major tax haven for both Asian (especially India) and African economies, and now ranking 8th overall. 3308:, also features as a major U.S. corporate tax haven; 6th most popular destination for U.S. corporate tax inversions. 2700: 18409: 17833: 17778: 16721: 16711: 16618: 13138: 12893: 11979: 10124: 10000: 8292: 8212: 8008: 6774: 6748: 6667: 5976: 5598: 3235:

Sovereign (including de facto) states that feature mainly as traditional tax havens (but have non-zero tax rates):

2467: 2463: 2298: 2154: 2150: 1793: 1765:

giving tax agencies knowledge to tax offshore income and assets. However very large and complex corporations, like

483: 14938: 14497: 12057: 18404: 18384: 18379: 17228: 16731: 16418: 15615: 14563: 13873:"Revealed: Project Goldcrest, how Amazon worked with the Luxembourg Government to avoid huge sums in tax with IP" 13582: 13390: 13047: 12677: 10693: 10577: 10571:"What Makes a Country a Tax Haven? An Assessment of International Standards Shows Why Ireland Is Not a Tax Haven" 7431: 6866: 5171:

Corporations can move their legal headquarters from a higher-tax home jurisdiction to a tax haven by executing a

3850:

These figures only include "financial assets" and do not include assets such as Real Estate, precious metals etc.

3833:(TJN), and as part of his analysis, chronicled the history of past financial estimates by various organisations. 3275: 1946:. The Zurich-Zug-Liechtenstein triangle expanded and was joined by Luxembourg in 1929 when they created tax-free 665: 261: 15876: 13945: 13468:

are likely to differ from those of U.S. firms and bear strong similarities to those of other G-7 and OECD firms.

11866: 7244: 5157:, the largest tax fine in history, they claimed Apple had received "preferential tax rulings" in 1991 and 2007. 18424: 18389: 18291: 16736: 16505: 16499: 15971: 15537: 14530: 14367: 13357: 12970: 12814: 11031: 10042: 8467: 8421: 8349: 7368: 6844: 6614: 6527: 6278: 6185: 6091: 5676: 4975: 3982: 3160: 2305:, from the 2017 investigation by the European Parliament, and from leading academic researchers of tax havens. 2290: 1622: 1341: 17982: 15345: 11348:"Multinationals channel more money through "hubs" in Singapore, Switzerland than ever before, Tax Office says" 9963: 7469: 2594: 1745:(illegal non-payment of taxes owed). These include the end of banking secrecy in many jurisdictions including 17753: 17163: 16613: 16511: 16471: 14849: 14818: 12866: 8822: 8651: 6487:

Papers marked (‡) were cited by the EU Commission 2017 summary as the most important research on tax havens.

6103: 5381: 5089:

There are a number of notable concepts in relation to how individuals and corporates engage with tax havens:

4981: 3640:– similar to the U.S., Germany can be included on lists for its tax secrecy, per the Financial Secrecy Index. 3615: 3583:(↕) Identified on the European Union's first 2017 list of 17 tax havens; the above list contains 8 of the 17. 2859: 2734: 2039: 1845: 1627: 586: 55: 11767: 7355:

Tax havens are typically small, well-governed states that impose low or zero tax rates on foreign investors.

3060: 2696: 2393:

In 2017, only Trinidad & Tobago met the 1998 OECD definition; that definition thus fell into disrepute.

2349:

Tax havens are typically small, well-governed states that impose low or zero tax rates on foreign investors.

2056:

that a British-registered company with no business activities in Britain is not liable to British taxation.

1808:

Use of tax havens results in a loss of tax revenues to countries which are not tax havens. Estimates of the

18310: 17862: 17630: 16864: 16673: 16663: 16557: 16447: 16002: 15881: 15650: 14853: 14400: 14123: 13313: 11956: 7968: 7089: 7034: 6107: 5387: 5078: 5039: 3992: 3873: 3762:

lost due to tax havens (estimated to be in the hundreds of billions of USD), and figures that focus on the

3631: 3301:, does feature as a U.S. corporate tax haven; only 2nd to Ireland as a destination for U.S. tax inversions. 3283: 2624: 1960:. Currency controls enacted post–World War II led to the creation of the Eurodollar market and the rise in 1325: 616: 15890: 7084: 4963: 3044:(Ireland, Singapore, Switzerland, the Netherlands, and the United Kingdom), in CORPNET's 2017 research; or 2322: 2102: 18124: 17282: 16854: 16829: 16766: 15781: 15691: 13178: 9306: 9130: 8907: 7252: 6640: 6584: 6554: 6358: 5246: 4986: 4008: 3572: 3190: 3041: 2498: 2225: 1567: 1537: 15282: 5272: 18306: 17793: 17307: 17156: 16368: 14794:"Texts adopted - Lessons learnt from the Pandora Papers and other revelations - Thursday, 15 June 2023" 14793: 14433: 8853:"Archaeology of a Treasure Island: Actors and Practices of Holding Companies in Luxembourg (1929–1940)" 8703: 6375: 5798: 5356: 5034:

Distribution of U.S. corporate profits (as a % of U.S. GDP) booked in foreign locations (BEA Data)

4902: 3703: 3382: 3337:– long-established very traditional European tax haven and just outside of the top 10 global Sink OFCs. 3119: 2849: 2742: 2505:, matched 9 of the top 10 havens in Hines' 2010 list, only differing in the United Kingdom, which only 2483: 2191: 2031: 2022:, however, the corporate-focused tax havens were drawn from the largest OFCs that had emerged from the 1965: 948: 420: 17: 15840: 15577: 14901: 12510: 11607: 3774:

Banking data. Estimating the amount of capital in the private and/or offshore banking system through

3578: 3223: 3216: 3205: 3194: 3186: 3059:

Of these ten major havens, all except the United Kingdom and the Netherlands featured on the original

3047: 2502: 2229: 18394: 17987: 17935: 17002: 16965: 16696: 16173: 12585: 11430: 10621: 9409:"Uncovering Offshore Financial Centers: Conduits and Sinks in the Global Corporate Ownership Network" 9175: 6721: 6026: 5706: 5700: 5336: 4985:

U.S. multinationals book over half of their non-U.S. profits in tax havens by using BEPS tools (2016

4943: 3977: 3906: 3385:

of 52 tax havens. It is shown below but expanded to 55 to include havens identified in the July 2017

3170: 2869: 2803: 2738: 2506: 2447: 2233: 2149:

using a qualitative list of criteria; in 2007, the IMF produced a revised quantitative-based list of

2142: 2134: 1961: 1899: 1766: 1754: 1735: 995: 573: 530: 381: 236: 85: 16389: 15498: 15378: 12846: 11932: 11893: 11110:

Amount of Tax Haven Connections (Figure 1, Page 11), Amount of Tax Haven Profits (Figure 4, Page 16)

7549: 3755:, they found Apple had used Irish ULLs to avoid filing Irish public accounts since the early 1990s. 17223: 16901: 16844: 16803: 16126: 15936: 15077: 13590: 13400: 13022: 9670:

New Gabriel Zucman study claims State shelters more multinational profits than the entire Caribbean

9040: 8350:"CRISIS RECOVERY IN A COUNTRY WITH A HIGH PRESENCE OF FOREIGN-OWNED COMPANIES: The Case of Ireland" 6874: 6697: 6371: 5668: 5332: 4803:

and the figures, where shown (marked by, ‡), are USD per capita for places that are not tax havens.

3900: 3695: 2685:(although the FSI is a list of "financial secrecy jurisdictions", and not specifically tax havens). 1828:, and the subsequent financial crisis in 2009–13, is an example. Jersey is another. Research shows 1587: 1005: 489: 15435: 14200: 9566: 9486: 9406: 9259: 8356: 5777:

Financial centres that have committed to – but not yet fully implemented – the standard (includes

3074:, this list, excluding Canada, contains all seven of the countries that received more than one US 18338: 18261: 18241: 17998: 17788: 17623: 17527: 17079: 16923: 16871: 16007: 15542: 13844: 11098: 10614: 10357: 9792: 7152: 6081: 6050: 6034: 5723: 5299: 5180: 3623: 3368: 3353: 2682: 2553: 2490: 2221: 2180: 2087: 1723: 1602: 1542: 1053: 1048: 670: 551: 202: 10697: 10677:

Some experts see no difference between tax havens and OFCs and employ the terms interchangeably.

7969:"Tax havens cost governments $ 200 billion a year. It's time to change the way global tax works" 7188: 5513:

Countries with politicians, public officials or close associates named in the leak in April 2016

3208:

in the world (a terminus for many corporate tax havens, especially Ireland and the Netherlands).

18419: 18399: 18190: 18038: 17676: 17592: 17467: 17109: 17099: 16982: 16918: 16849: 16834: 16759: 16138: 15850: 15657: 12948: 9302: 7735:"Standard for Automatic Exchange of Financial Account Information in Tax Matters | READ online" 7710:"Standard for Automatic Exchange of Financial Account Information in Tax Matters | READ online" 7685:"Standard for Automatic Exchange of Financial Account Information in Tax Matters | READ online" 7660:"Standard for Automatic Exchange of Financial Account Information in Tax Matters | READ online" 7635:"Standard for Automatic Exchange of Financial Account Information in Tax Matters | READ online" 7592:"Standard for Automatic Exchange of Financial Account Information in Tax Matters | READ online" 7544: 6440:

The U.S. refused to sign the OECD BEPS Multilateral Instrument ("MLI") on the 24 November 2016.

6175: 6075:

system" to a "territorial tax system", and created new IP-based BEPS tools including a low-tax

4850: 3769:

As of March 2019, the most credible methods used for estimating the financial scale have been:

3291: 3034:(*) Appears as a top ten tax haven in all three lists; 9 major tax havens meet this criterion, 2837:

as: "Ireland, Luxembourg, Netherlands, Switzerland, Singapore, Bermuda and Caribbean havens".

2124:

2000: The OECD produces its first formal list of 35 tax havens who have met two of three OECD

1687: 1512: 1397: 1392: 988: 567: 386: 16638: 15826: 13170: 12944: 12112: 10748:"What Do We Know About Base Erosion and Profit Shifting? A Review of the Empirical Literature" 5572: 5528: 5491: 5030: 3112:

in all three quantitative lists, Hines 2010, ITEP 2017 and Zucman 2018 (above); all nine such

2224:'s CORPNET group using on a purely quantitive approach, splits the understanding of OFCs into 18266: 18256: 18236: 18084: 18058: 17961: 17732: 17407: 17245: 16977: 16906: 16363: 16143: 16106: 15499:"Two years after the 'double Irish' was shelved, Google used it to shift billions to Bermuda" 10751: 6379: 6190: 6000: 5590:

In October 2021, 11.9 million leaked documents with 2.9 terabytes of data were leaked by the

5555: 5293: 5223: 4819: 3973: 3895:

shielded from taxation via BEPS activities carried out through tax haven type jurisdictions.

3822: 3731: 3386: 3228: 3156: 3145: 3102: 3071: 3050:(British Virgin Islands, Luxembourg, Hong Kong, Jersey, Bermuda), in CORPNET's 2017 research. 2757: 2719: 2510: 2210: 2035: 1969: 1802: 1592: 1517: 1482: 1467: 1387: 1377: 621: 541: 536: 457: 14823:"Treasury and IRS Issue Guidance Outlining Phased Implementation of FATCA Beginning in 2013" 14822: 11172: 5509: 3287:, see table opposite, where 17 of the 24 Sink OFCs are current, or past, U.K. dependencies: 18414: 18286: 18165: 18020: 17855: 17763: 17532: 17437: 17250: 17218: 17208: 17193: 17094: 17089: 17032: 16061: 15986: 14187:

Intellectual property (IP) has become the leading tax avoidance vehicle in the world today.

13218: 13113: 11233:"Google's new APAC headquarters in Singapore is a blend of office building and tech campus" 11096: 10221: 10219: 9432: 6085:

reported that "In U.S. tax inversion Deals, U.K. is now a winner". In a 2015 presentation,

6014: 5917: 5881: 5754:

Tax havens that have committed to – but not yet fully implemented – the standard (includes

5343:

is a major wrapper in the global securitization market. This SPV offers features including

5188: 4917: 4542: 4227: 3315:– like the Isle of Man, has declined due to concerns, even by the U.K., over its practices. 3173:; 17 of the 24 Sink OFCs are current or former dependencies of the UK (see Sink OFC table). 3079: 2826: 1612: 1577: 1552: 1432: 1412: 579: 256: 117: 15473:"Ireland's move to close the 'Double Irish' tax loophole unlikely to bother Apple, Google" 14630:"Luxembourg tax files: how tiny state rubber-stamped tax avoidance on an industrial scale" 13904: 10119: 5826:

Government response to the crackdown has been broadly supportive, although not universal.

5422: 3660:

to the U.S. or Germany for tax purposes, a basic characteristic of a corporate tax haven.

3274:(United Kingdom dependency), the "failing tax haven", not in the CORPNET study (discussed 2064:

even made inquiry or research into the "trade secrets" of Swiss banks, a criminal offense.

8: 18353: 18314: 18160: 18114: 18089: 17956: 17951: 17919: 17069: 17059: 17054: 17037: 16928: 16911: 16824: 16168: 15929: 15440: 14297: 14128: 13911: 13802: 13661: 12681: 12445: 12408: 12371: 12226: 12183: 12025: 11061: 11035: 10743: 10115: 9407:

Javier Garcia-Bernardo; Jan Fichtner; Frank W. Takes; Eelke M. Heemskerk (24 July 2017).

9341: 9283: 8900: 8596: 8109:"Every cent lost to tax havens could be used to strengthen our health and social systems" 7476: 7397: 7236: 6676: 6593: 6392: 6170: 6165: 6006: 5944: 5909: 5830: 5426: 5355:, as it could damage the local tax base, but are needed by banks in securitizations. The 5176: 4563: 4164: 3936: 3830: 3691: 3649: 3243: 3134: 2795: 2549: 2438: 2409: 2331: 2294: 2268: 2176: 1919: 1785: 1632: 1532: 1527: 1472: 1457: 1447: 1442: 1437: 1382: 1372: 1367: 1351: 1221: 1167: 970: 478: 17312: 15822: 9788:"Corporations Push Profits Into Tax Havens as Countries Struggle in Pursuit, Study Says" 9436: 7209:

a place where people pay less tax than they would pay if they lived in their own country

4938:

to jurisdictions with normal tax regimes, that can damage their economies. In addition,

4915:

Andrew K. Rose, Mark M. Spiegel, "Offshore Financial Centers: Parasites or Symbionts?",

3963:

List of countries by GDP (PPP) per capita § Distorted GDP-per-capita for tax havens

3836:

Henry used mainly global banking data from various regulatory sources to estimate that:

3785:

National accounts data. Estimating the amount of capital that is unreconciled in global

3751:) that may be used for secrecy of UBOs. For example, when the EU Commission discovered 1926:

identifies two of the three major groups of tax havens, as emerging during this period:

18296: 18150: 18145: 17773: 17377: 17203: 17151: 17114: 16859: 16569: 16251: 16111: 16056: 14467:"ICIJ Releases Offshore Leaks Database Revealing Names Behind Secret Companies, Trusts" 13322: 13130: 13039: 12480: 11720:"Deloitte promotes Mauritius as tax haven to avoid big payouts to poor African nations" 10726:

Yet today it is difficult to distinguish between the activities of tax havens and OFCs.

10504: 10046: 9455: 9422: 9408: 9054: 7334: 7269: 6783: 6680: 6610:"The Missing Wealth of Nations: Are Europe and the U.S. Net Debtors or Net Creditors?" 6597: 6567: 6536: 6273: 6111: 5563: 5559: 5212: 5204: 5057: 5000: 4893: 4878: 3940: 3923: 3645: 3253:– an emerging tax haven inside the EU, which has been a target of wider media scrutiny. 2620: 2459: 2354: 2326: 2187: 2098: 2014: 1914: 1908: 1894:

sometimes claims to have been the first tax haven based upon the creation of the first

1607: 1597: 1582: 1572: 1547: 1497: 1462: 1452: 1422: 1407: 1402: 1257: 1172: 960: 924: 845: 724: 442: 80: 15871:

An OECD Proposal to Eliminate Tax Competition Would Mean Higher Taxes and Less Privacy

13859:

Chapter 21. Troubling tax havens: Tax footprint reduction and jurisdictional arbitrage

11808:"SAMOA: Ranked No.1 as world's most secretive tax haven, potential for more investors" 10349: 9699: 7528:"The Missing Wealth of Nations: Are Europe and The U.S. Net Debtors or Net Creditors?" 6451:

Ireland, Luxembourg, Netherlands, Switzerland, Singapore, Bermuda and Caribbean havens

3614:(United States), almost a corporate tax haven "concession" by the U.S., but which the 2157:, who are responsible for 85% of OFC financial flows. By 2010, tax academics consider 18358: 18329: 18109: 18053: 17565: 17432: 17317: 17198: 17104: 16970: 16876: 16299: 16246: 16074: 16069: 15981: 15776: 15692:"A Hybrid Approach: The Treatment of Foreign Profits under the Tax Cuts and Jobs Act" 13848: 13594: 13562: 13436: 13404: 13134: 13126: 13035: 12567: 12108: 11404:"Bermuda? Guess again. Turns out Holland is the tax haven of choice for US companies" 10961: 10703: 9460: 9075: 9044: 9006: 8870: 8766: 8746: 8707: 8435: 8416: 8288: 8239: 8203: 7527: 7308: 7240: 7067: 7048: 6990: 6953: 6929: 6905: 6878: 6848: 6820: 6813: 6200: 5567: 5523: 5352: 5348: 5344: 3786: 3748: 1680: 1522: 1507: 1502: 1477: 1427: 1227: 938: 890: 830: 746: 687: 399: 366: 172: 15725: 13688: 13043: 12220:"Revealed: Global super-rich has at least $ 21 trillion hidden in secret tax havens" 11782:"Liechtenstein: The mysterious tax heaven that's losing the trust of the super-rich" 10654: 10508: 10482:"Tax treaty shopping: structural determinants of FDI routed through the Netherlands" 7338: 7273: 5739:

Those that have substantially implemented the standard (includes most countries but

5643:

International. Where multiple countries decide to change the basis of fair taxation.

5479: 3344:– acts as both a traditional tax haven (ranked 12th Sink OFC), and ranks 8th on the 2784:

countries are tax havens, led by: Luxembourg (#1), Singapore (#2), and Ireland (#3).

1711:

is a term, often used pejoratively, to describe a place with very low tax rates for

18205: 18170: 18015: 17883: 17712: 17472: 17452: 17367: 17292: 17121: 16992: 16891: 16633: 16343: 16314: 16201: 16131: 16121: 16101: 15790: 15218: 13984: 13953: 13794: 13754: 13653: 13122: 13031: 13015:"In praise of tax havens: International tax planning and foreign direct investment" 12923: 12746: 12710: 12559: 12434: 12400: 12360: 12215: 11441: 11027: 10817: 10496: 10300:"TAX CUTS AND JOBS ACT OF 2017 Corporate Tax Reform and Wages: Theory and Evidence" 9833: 9747:"Half of U.S. foreign profits booked in tax havens, especially Ireland: NBER paper" 9450: 9440: 9413: 8996: 8860: 8565: 8430: 8307: 8017: 7891: 7873:

Such profit shifting leads to a total annual revenue loss of $ 250 billion globally

7554: 7326: 7261: 6919: 6808: 6288: 6155: 5929: 5809: 5430: 5231: 5129: 4926:

However, other notable tax academics strongly dispute these views, such as work by

2611:, the United Kingdom created its first "non-resident company" in 1929, and led the 1982: 1973: 1895: 1877: 1792:

compliance, and thus have large networks of bilateral tax treaties. However, their

1780:, are open about zero rates of taxation – as a consequence they have few bilateral 1562: 1487: 1093: 1058: 1038: 850: 818: 692: 546: 297: 15794: 14986: 14955: 13981:"Zo werd Nederland het grootste belastingparadijs voor Amerikaanse multinationals" 9058: 7265: 5199:

Even when a corporation executes a tax inversion to a tax haven, it also needs to

3363:– a traditional tax haven (ranked 14th Sink OFC), used to have one of the highest 2009:

to Panama. The EU Commission showed that Apple Inc. had begun to use the infamous

17992: 17869: 17783: 17604: 17555: 17487: 17462: 17427: 17342: 17213: 17131: 17049: 16958: 16886: 16839: 16590: 16294: 16289: 15966: 15903: 15084: 14854:"Do I need to file Form 8938, "Statement of Specified Foreign Financial Assets"?" 14275: 14016: 12853: 11840: 11549: 9751: 9491: 9264: 8460: 7119: 7080: 6983: 6815:

Capitalism's Achilles' Heel: Dirty Money, and How to Renew the Free-Market System

6234: 5924:

above. The EU lists did not include any OECD or EU jurisdictions, or any of the

5812: 5549: 5519: 5340: 3122:

of 52 tax havens; 17 of the 20 locations below, are on the James Hines 2010 list.

2841:

Comparison of top ten tax havens from the major quantitative studies since 2010:

2715: 2494: 2169: 2121:

tax rates were much lower. Hines shows that the US is a major user of tax havens.

1977: 1770: 1656: 1272: 1130: 1125: 860: 823: 734: 699: 601: 525: 361: 321: 287: 197: 187: 182: 177: 95: 31: 14696:"HSBC whistleblower given five years' jail over biggest leak in banking history" 11462:"Scientists have found a way of showing how Malta is a global top ten tax haven" 11309:

Study claims State shelters more multinational profits than the entire Caribbean

10390: 5601:

regarding the conduct and publicity surrounding the Pandora Papers data breach:

5315:, which are traditional tax havens to which corporates route untaxed funds, and 4818:"Conduit OFC" and "Sink OFC" refers to University of Amsterdam's CORPNET's 2017 3953:, such as the Tax Justice Network, who accused them as promoting tax avoidance. 18246: 18215: 18185: 17818: 17702: 17646: 17457: 17322: 17297: 17168: 17014: 16953: 16808: 16348: 16304: 16221: 15885: 15856:

Global Forum on Transparency and Exchange of Information for Tax Purposes, OECD

15845: 15772: 15729: 15695: 15584: 15533: 14438: 14156: 13488: 12975: 12919: 12324: 12172: 12014: 11176: 10813: 10307: 9864:"The Netherlands is a tax haven alongside Ireland, Malta, and Cyprus, say MEPs" 9695: 9609: 9445: 9370: 9227: 8901:"Concept of Offshore Financial Centers: In Search of an Operational Definition" 8068: 7999: 7523: 6943: 6800: 6757: 6731: 6623: 6563: 6293: 6161:

Association for the Taxation of Financial Transactions and for Citizens' Action

5853: 5585: 5412: 5208: 5108: 5018: 4951: 4846: 4833: 3826: 3790: 3653: 3305: 3166: 2799: 2537: 2525: 2252: 2209:

complete the largest hybrid-tax inversion in history moving US$ 300 billion of

2201:

completes the largest tax inversion in history in a US$ 48 billion merger with

1992: 1712: 1215: 1187: 1162: 1023: 865: 660: 596: 494: 432: 336: 331: 314: 292: 15164:. The International Consortium of Investigative Journalists. 5 December 2017. 13435: 12359: 10500: 8865: 8146: 8041: 7307: 5852:

adopted a "blacklist" of territories to encourage compliance and cooperation:

5147:, started in 1998; by 2019, the OECD had investigated over 255 PTRs. The 2014 2441:, "What Problems and Opportunities are created by Tax Havens?" (December 2008) 18373: 18334: 18324: 18104: 18094: 18074: 18025: 17909: 17813: 17722: 17717: 17570: 17522: 17517: 17512: 17507: 17492: 17402: 17372: 17332: 17240: 17007: 16881: 16782: 16268: 16211: 15771: 15503: 15459:

Ireland become a hub for American tech and pharma giants operating in Europe.

15131: 13577: 13527:"White House Push to Help Workers Through Corporate Tax Cut Draws Skepticism" 13385: 12590: 12571: 12563: 12255: 12064: 11519:"Malta is a target for Italian mafia, Russia loan sharks, damning probe says" 10228: 10220:

Vincent Bouvatier; Gunther Capelle-Blancard; Anne-Laure Delatte (July 2017).

9337: 8874: 8243: 6861: 6396: 6283: 6220: 6210: 5849: 5688: 5597:

In a report dated 15 June 2023, certain chilling admissions were made by the

5533: 5504: 5172: 5166: 4649: 4313: 3758:

Additionally, there is sometimes confusion between figures that focus on the

3657: 3601: 3334: 3075: 2770: 2766: 2272: 2240: 2083: 2057: 2006: 1937: 1832:, and use of tax havens by U.S corporates maximised U.S. exchequer receipts. 1287: 955: 880: 771: 704: 638: 606: 473: 415: 376: 356: 326: 241: 162: 157: 132: 122: 64: 12714: 10951:

Final report of the independent Review of British offshore financial centres

9993: 8312: 7114: 5947:

voted by 505 in favour to 63 against of accepting a new report that likened

18301: 18180: 18175: 18099: 17697: 17550: 17477: 17447: 17392: 17302: 17074: 16309: 16261: 16256: 16216: 16116: 16086: 16037: 15895: 14900:

Watt, Nicholas; Elliott, Larry; Borger, Julian; Black, Ian (2 April 2009).

14766: 14733: 14700: 14667: 14634: 14601: 14568: 14535: 14502: 14405: 14372: 13877: 13763: 13759:"Britain can't prosper as a tax haven. It has to stop these hollow threats" 13693: 13350: 13166: 12138: 11058:"Blacklist, whitewashed: How the OECD bent its rules to help tax haven USA" 11002: 10222:"Banks in Tax Havens: First Evidence based on Country-by-Country Reporting" 9613: 9464: 8077: 6649: 6254: 6239: 6145: 6102:

The US followed a broadly similar reform to the UK with the passing of the

5485: 5263: 4927: 4670: 4334: 3997: 2822: 2214: 2202: 2010: 1825: 1719: 1668: 1182: 965: 934: 905: 885: 776: 761: 741: 655: 650: 452: 246: 15162:"Where is Luxembourg, Ireland and the Netherlands on the new EU blacklist" 14335:"Liechtenstein's Shadowy Informant: Tax Whistleblower Sold Data to the US" 11097:

Richard Phillips; Matt Gardner; Alexandria Robins; Michelle Surka (2017).

9002:

Treasure Islands: Uncovering the Damage of Offshore Banking and Tax Havens

6925:

Treasure Islands: Uncovering the Damage of Offshore Banking and Tax Havens

6835: 6047:

fined Apple €13 billion for using an illegal hybrid-Double Irish structure

5683:

who have foreign financial assets in excess of $ 50,000 to complete a new

3622:

Major sovereign States which feature on financial secrecy lists (e.g. the

215: 18155: 18079: 17823: 17727: 17560: 17442: 17397: 17387: 17337: 17327: 17277: 17084: 16273: 16231: 16226: 16191: 16158: 16041: 15855: 14762:"Paradise Papers leak reveals secrets of the world elite's hidden wealth" 14339: 13831: 13623: 13578: 13386: 13309: 13308: 12651: 12623: 12547: 10957: 10689: 10650: 10541:"Activists and experts ridicule OECD's tax havens 'blacklist' as a farce" 9932: 8818: 8690: 8647: 8022: 8003: 7558: 7330: 6892: 6862: 6244: 6215: 6195: 5960: 5901: 5873: 5801: 5672: 5457: 5316: 5099: 5052: 4712: 4584: 4355: 4248: 3736: 3677: 3611: 3270: 3182: 3152: 2628: 2376:

Global Forum on Transparency and Exchange of Information for Tax Purposes

1923: 1887: 1873: 1872:. In the 1880s, New Jersey was in financial difficulty and the governor, 1762: 1746: 1742: 1177: 915: 875: 793: 729: 675: 611: 437: 427: 371: 251: 152: 147: 105: 90: 15915: 15433: 15346:"Ireland likened to tax haven in report accepted in European Parliament" 15101:"EU blacklist names 17 tax havens and puts Caymans and Jersey on notice" 14663:"HSBC: Swiss bank searched as officials launch money-laundering inquiry" 13105: 11867:"Puerto Rico Governor: GOP tax bill is 'serious setback' for the island" 9964:"Ireland likened to tax haven in report accepted in European Parliament" 3630:

United States – noted for secrecy, per the Financial Secrecy Index (see

3129:

Sovereign states that feature mainly as major corporate tax havens are:

3101:

research on tax havens is the University of Amsterdam CORPNET July 2017

18200: 17748: 17502: 17497: 17362: 17287: 17146: 17064: 17044: 16726: 16547:

Commission for the Prevention of Corruption of the Republic of Slovenia

16241: 16196: 16153: 15952: 14931: 12918: 12856:, World Bank. Database updated on 1 July 2017. Accessed on 2 July 2017. 11322:"Ireland: Where Profits Pile Up, Helping Multinationals Keep Taxes Low" 9608: 8004:"Taxing across Borders: Tracking Personal Wealth and Corporate Profits" 6492: 6076: 5948: 5782: 5755: 5104: 4456: 4292: 4101: 4019: 3844:

USD 190 to 255 billion in annual tax revenues are lost due to i. above;

3681: 3626:), but not on corporate tax haven or traditional tax haven lists, are: 3201: 3067:

subcategory; highlighting a lack of progress in curtailing tax havens.

2810: 2647:

lists, both Taiwan and Mauritius rank in the top ten global Sink OFCs.

2513:

study split the understanding of a tax haven into two classifications:

2470:

who handle 85% of all flows. From about 2010, tax academics considered

2206: 1820:

countries, excluding oil and gas exporters, are tax havens. Because of

1781: 1282: 1252: 1135: 1120: 1043: 975: 943: 895: 870: 855: 756: 751: 719: 645: 351: 346: 167: 127: 73: 14498:"Offshore Leaks app puts secret users of tax havens in the public eye" 14063:"Harmful Tax Practices - 2018 Progress Report on Preferential Regimes" 12847:

PPP (current international $ )", World Development Indicators database

11608:"Top tax haven got more investment in 2013 than India and Brazil: U.N" 11431:"Do Multinationals or Domestic Firms Face higher Effective Tax Rates?" 6061:

reform of the US corporate tax code by the 2017 TCJA may change this.

5804:

had suggested earlier that Malaysia should not be in the bottom tier.

3886:

in developing countries, while they would fall by 55% in tax havens."

3327: 2586:

lists, namely: the Netherlands, Ireland, Switzerland, and Luxembourg.

18195: 18119: 17828: 17707: 17173: 16896: 16091: 16051: 16032: 15865: 12647:"Is it true to say Ireland is one of the world's biggest tax havens?" 11289:"Ireland is the world's biggest corporate 'tax haven', say academics" 9650:"Ireland is the world's biggest corporate 'tax haven', say academics" 8042:

Jannick Damgaard; Thomas Elkjaer; Niels Johannesen (September 2019).

7763:"Netherlands and UK are biggest channels for corporate tax avoidance" 7235: 6268: 6205: 5816: 5778: 5744: 5731: 5442: 5149: 5116: 4627: 4500: 4270: 4122: 3581:

by CORPNET in 2017; the above list has 23 of the 24 (Guyana missing).

3321: 3312: 3219:

as Luxembourg; tied to APAC's largest corporate tax haven, Singapore.

3212: 3141: 2198: 1115: 1033: 1028: 714: 709: 447: 137: 14729:"What are the Panama Papers? A guide to history's biggest data leak" 14271:"Ireland is a tax haven — and that's becoming controversial at home" 14205:

Fordham Intellectual Property, Media & Entertainment Law Journal

11738:"Rise of tax haven Mauritius comes at the expense of rest of Africa" 9367:"Tax Reform in the UK Reversed the Tide of Corporate Tax Inversions" 6974: 6717:"End of Bank Secrecy: An Evaluation of the G20 Tax Haven Crackdown" 5390:

paid €4.2 million to Heinrich Kieber, a former IT data archivist of

18348: 18140: 17977: 16236: 16206: 15976: 15349: 15319: 15286: 13728: 13547:

But the CEA did not misinterpret the Desai, Foley, and Hines paper.

12514: 12329: 12260: 11554: 11446: 10787: 9967: 9427: 8513:

Damgaard, Jannick; Elkjaer, Thomas; Johannesen, Niels (June 2018).

6249: 5982: 5937: 5885: 5861: 5465: 5391: 5312: 5307: 5111:

BEPS tool, which Dutch law firms then marketed to US corporations:

3597: 3397:

above, show OECD processes focus on the compliance of tiny havens.

2818: 1277: 1245: 929: 919: 840: 835: 808: 781: 591: 341: 282: 277: 110: 15578:

Tax Reform in the UK Reversed the Tide of Corporate Tax Inversions

10702:. Cornell Studies in Money. Cornell University Press. p. 24. 8593:"New UN tax handbook: Lower-income countries vs OECD BEPS failure" 7796:"Is the U.K. Already the Kind of Tax Haven It Claims It Won't Be?" 7428:"Ireland's playing games in the last chance saloon of tax justice" 7023:"Sun and Shadows: How an Island Paradise Became a Haven for Money" 3348:

profits list (figure 4, page 16) of corporate havens; 3rd highest

2345:

on governance, which is broadly accepted in the academic lexicon.

2105:, producing the first academic list of 41 tax havens, including 7 17914: 17615: 16148: 16046: 15405:"State aid SA.38373 (2014/C) (ex 2014/NN) — Alleged aid to Apple" 15255: 12715:"Tax havens' arguments in their defence – and why they are wrong" 12405:"Tax haven of Jersey to attack TJN with funded study. We respond" 12293: 5956: 5913: 5889: 5865: 5857: 5792:

Those that have not committed to the standard (an empty category)

5786: 5771: 5303: 4754: 4733: 4691: 4397: 4376: 3714: 3707: 3687: 3673: 3637: 3341: 3298: 1891: 1088: 910: 813: 803: 142: 100: 16751: 15188:"EU's Moscovici slams Ireland, Netherlands as tax 'black holes'" 14093:"EU Commissioner to brief Finance Committee on Apple tax ruling" 11639:"China's princelings storing riches in Caribbean offshore haven" 10350:"Firms, Trade and Profit Shifting: Evidence from Aggregate Data" 9077:

Tax Havens and their use by United States Taxpayers, An Overview

9035:

Jason Sharman (2006). "The Struggle for Global Tax Regulation".

6318:

that excludes sufficient items from taxable income to bring the

3766:

residing in tax havens (estimated to be many trillions of USD).

3082:). In addition, six of these major tax havens are in the top 15 2666:

Three main types of tax haven lists have been produced to date:

2657:

Offshore financial centre § Offshore Financial Centre lists

2341:

Hines refined his definition in 2016 to incorporate research on

2069:

Tax havens and their use by United States taxpayers: An Overview

17692: 17599: 16476: 13946:"DE CORRESPONDENT REVEALS HOW THE NETHERLANDS BECAME TAX HAVEN" 13725:"Malta is a captured state, say sons of Daphne Caruana Galizia" 9346:

There is no generally agreed definition of what a tax haven is.

6744:"Taxing Across Borders: Tracking Wealth and Corporate Profits" 6357:, and does not score some of the most common secrecy tools—the 5964: 5897: 5767: 5679:(TIN) of any U.S. owner. FATCA also requires U.S. citizens and 5406: 5055:, "The Global Con Hidden in Trump's Tax Reform Law, Revealed", 4775: 4605: 4521: 4206: 4185: 4143: 3669: 3262: 3239: 2814: 2374:

they were now all considered to have engaged in the OECD's new

1777: 1651: 1297: 1108: 1103: 1098: 900: 788: 15251:"EU tax haven blacklist set to shrink further, causing outcry" 13830: 11378:"Google's 'Dutch Sandwich' Shielded 16 Billion Euros From Tax" 10347: 9897:"Seven EU Countries Labeled 'Tax Havens' in Parliament Report" 9260:"Trinidad & Tobago left as the last blacklisted tax haven" 8414: 7467: 5928:. A few weeks later in January 2018, EU Taxation Commissioner 5562:, covering 19 tax havens, were leaked to the German reporters 4968:

low foreign tax rates ultimately enhance U.S. tax collections

1788:

have non-zero "headline" rates of taxation and high levels of

17838: 16436: 16096: 15921: 15434:

Alex Barker; Vincent Boland; Vanessa Houlder (October 2014).

14848: 14817: 14009: 13949: 13616: 13103: 10784:"The countries which are conduits for the biggest tax havens" 10160:"Blacklisted by Brazil, Dublin funds find new ways to invest" 10064:"Understanding the rationale for compiling 'tax haven' lists" 8763:

Tolley's International Initiatives Affecting Financial Havens

6663:"What Problems and Opportunities Are Created by Tax Havens?" 6054: 5952: 5905: 5893: 5877: 5820: 5759: 5748: 5740: 5361: 5125: 4478: 4435: 4079: 4057: 3744: 3360: 3250: 3242:– major traditional tax haven for APAC, and described by the 2829:". In September 2018, using TCJA repatriation tax data, the 2773:

since 1983 are: Ireland (#1), Bermuda (#2) and the U.K. (#3);

2091: 2067:

1981: The US Treasury and the US Attorney General are given:

1312: 1307: 1302: 1292: 1267: 1262: 1209: 1081: 15866:

Task Force on Financial Integrity & Economic Development

15078:"Tax haven clampdown yields cash but secrecy still thrives." 11636: 10120:"What Problems and Opportunities are Created by Tax Havens?" 8952:"The real Goldfinger: the London banker who broke the world" 6985:

The Blood Bankers: Tales from the Global Underground Economy

6523:"Fiscal Paradise: Foreign Tax Havens and American Business" 3976:

of a tax haven. At the core of the FSF-IMF definition of an

1840:

many member states of the European Union, departed from the

16081: 15918:—Sarah Anderson, Scott Klinger, Javier Rojo (June 12, 2013) 15860: 14066: 13722: 13508: 13318:"The Global Con Hidden in Trump's Tax Reform Law, Revealed" 10920:"How the U.S. became one of the world's biggest tax havens" 10327: 9694: 9224:"McDermott International: The Greatest Tax Story Ever Told" 9176:"Fiscal Paradise: Foreign Tax Havens and American Business" 9173: 8153: 7935: 7017:"Hidden in Plain Sight: New York Just Another Island Haven" 6086: 5869: 5763: 5471: 5399: 3809: 3797: 2877: 2533: 2455: 2387: 1789: 1758: 30:"Tax heaven" redirects here. For the dating simulator, see 16472:

Special Investigation Service of the Republic of Lithuania

14298:"IRISH FUNDS ASSOCIATION: ICAV Breakfast Seminar New York" 13165: 11690:"Defend Gibraltar? Better condemn it as a dodgy tax haven" 7029:"Leaked Records Reveal Offshore Holdings of China's Elite" 7011:"New Bank Leak Shows How Rich Exploit Tax Haven Loopholes" 6977:, CEPR Discussion Papers 9154, C.E.P.R. Discussion Papers. 5042:, realised the scale of U.S. corporate use of tax havens: 2153:, and in 2018, another revised quantitative-based list of 15612: 15283:"EU tax haven blacklist drops to five as Namibia removed" 14564:"Leaks reveal secrets of the rich who hide cash offshore" 14531:"Offshore secrets: unravelling a complex package of data" 14121: 12894:"Profits of US firms in Ireland at 800% of payroll costs" 12619:"Almost two-thirds of Irish FDI is 'phantom' – IMF study" 12084:

Brussels. 30.8.2016 C(2016) 5605 final. Total Pages (130)

10858:"The World's Favorite New Tax Haven Is the United States" 10688: 9037:

Havens in a Storm: The Struggle for Global Tax Regulation

8512: 7394:"New report: is Apple paying less than 1% tax in the EU?" 5727: 5395: 5306:

research group published the results of their multi-year

3775: 2138: 1836: 1734:

has led academics to note that the term "tax haven" and "

47: 16669:

International Association of Anti-Corruption Authorities

15779:(February 2006). "The demand for tax haven operations". 15571: 15569: 14231:"U.S. Chamber International IP Index, 6th Edition, 2018" 12842: 12840: 12511:"Half of US foreign profits booked in tax havens: paper" 12094: 12092: 11768:"EU RELEASES TAX HAVEN BLACKLIST; NETHERLANDS NOT ON IT" 6495:, ranked by academic citations, over the last 25 years. 5132:, "How the Netherlands became a Tax Haven", 31 May 2017. 5115:

former venture-capital executive at ABN Amro Holding NV

2312: 15316:"EU adds 10 countries, including UAE, to tax blacklist" 13870: 13658:"Seychelles: the ex-billionaire and the captured state" 13214:"How tax havens turn economic statistics into nonsense" 12867:"World Bank, International Comparison Program database" 12785:"How tax havens turn economic statistics into nonsense" 12546:

Tèrslèv, Thomas; Wier, Ludvig; Zucman, Gabriel (2022).

11429:

Markle, Kevin S.; Shackelford, Douglas A. (June 2009).

6949:

The Hidden Wealth of Nations: The Scourge of Tax Havens

3871:

In 2015, French tax economist Gabriel Zucman published

3676:

formerly had a reputation as the only tax haven in the

3056:

Kingdom (a major Conduit OFC) still in transformation.

15436:"Brussels in crackdown on 'Double Irish' tax loophole" 14899: 14303:. Irish Funds Association. November 2015. p. 16. 14157:"Intellectual Property Law Solutions to Tax Avoidance" 13012: 9928:"Is Ireland a tax haven? European Parliament says yes" 9528:"Outbreak of 'so whatery' over EU tax haven blacklist" 8938:

Tangier/Gibraltar – A Tale of One City: An Ethnography

6693:"In Praise of Tax Havens: International Tax Planning" 3863: 3656:. There are no known cases of foreign firms executing 1906:

corporate vehicle, while Zurich and Zug developed the

16466:

Governance and Economic Management Assistance Program

16425:

Independent Commission Against Corruption (Hong Kong)

15566: 14471: