The Magnitude of Corporate Profit Shifting
This section examines the evidence on the existence and magnitude of profit shifting and the
techniques that are most likely to contribute to it.
Evidence on the Scope of Profit Shifting
There is ample, and simple, evidence that profits appear in countries inconsistent with an
economic motivation. This section first examines the profit share of income of controlled
corporations compared to the share of gross domestic product and how it has changed recently
The first set of countries, acting as a reference point, includes the remaining G-7 countries that
are also among the United States’ major trading partners. These countries account for 12% of
pretax profits and 21% of rest-of-world gross domestic product. The second group of countries
includes larger countries from Table 1 (with gross domestic product [GDP] of at least $15
billion), plus the Netherlands, which is widely considered a tax conduit for U.S. multinationals
because of its holding company rules. These countries account for about 40% of earnings and 4%
of rest-of-world GDP. The third group of countries includes smaller countries listed in Table 1,
with GDP less than $10 billion. These countries account for 18% of earnings and less than onetenth
of 1% of rest-of-world GDP.61
As indicated in Table 2, income-to-GDP ratios in the large G-7 countries in 2010 ranged from
0.2% to 3.3%, the larger amounts reflecting in part the United States’ relationships with some of
its closest trading partners. Overall, this income as a share of GDP is 0.7%. Outside the UK and
Canada, this income as a share of GDP is around 0.3% to 0.6% and does not vary with country
size (Japan, for example, has over twice the GDP of Italy). Canada and the UK also have
appeared on some tax haven lists, and the larger income shares could partially reflect that fact.62
There has been relatively little change in the aggregate between 2004 and 2010 (the latest year
IRS data on earnings of multinational firms are available).