Developing Countries, tax Treaty Shopping and the Global Minimum Tax

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh, Egypt, Indonesia, Kenya, Uganda and Zambia, are vulnerable to substantial potential losses of withholding tax revenue by treaty shopping. The analysis combines tax parameters of more than a hundred countries with an algorithm from network theory, which simulates the tax minimizing behaviour of multinational enterprises. We introduce the notion of potentially aggressive tax treaties. These are the key treaties in treaty shopping routes, that may lead to substantial tax revenue losses in developing countries. Moreover, under the rules of the global minimum tax, the treaty partners are often in a prime position to top-up tax undertaxed profits of developing countries that offer tax incentives to attract investment, thus nullifying the incentive effects.

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Publication Details

Journal
Public Finance Review
Published
2025-04-24
DOI
https://doi.org/10.1177/10911421251334849
Primary Topic
Corporate Taxation and Avoidance
Type
article
Field-Weighted Citation Impact
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article

Developing Countries, tax Treaty Shopping and the Global Minimum Tax

Arjan Lejour, Maarten van ’t Riet
Public Finance Review
Corporate Taxation and Avoidance
article

Developing Countries, tax Treaty Shopping and the Global Minimum Tax

Arjan Lejour, Maarten van ’t Riet
article en

Abstract

Analysis of the international network of double tax treaties reveals a large potential for tax avoidance. Developing countries are, on average, not more likely to suffer from tax revenue losses than other countries. Yet, this average masks the fact that several countries, such as Bangladesh, Egypt, Indonesia, Kenya, Uganda and Zambia, are vulnerable to substantial potential losses of withholding tax revenue by treaty shopping. The analysis combines tax parameters of more than a hundred countries with an algorithm from network theory, which simulates the tax minimizing behaviour of multinational enterprises. We introduce the notion of potentially aggressive tax treaties. These are the key treaties in treaty shopping routes, that may lead to substantial tax revenue losses in developing countries. Moreover, under the rules of the global minimum tax, the treaty partners are often in a prime position to top-up tax undertaxed profits of developing countries that offer tax incentives to attract investment, thus nullifying the incentive effects.

Public Finance ReviewVol. 53(6)
Leiden University (NL), Tilburg University (NL), CPB Netherlands Bureau for Economic Policy Analysis (NL)
Openalex Percentile: Top 88%
Corporate Taxation and Avoidance
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