Understanding the interaction of motivation and opportunity for tax planning inside US multinationals: a qualitative study

We explore the internal workings of tax planning within US multinational enterprises (MNEs) using a qualitative research method. We conduct a series of interviews with senior tax executives, supplemented with other public information. We find that US MNEs adopt a heterogenous range of approaches driven by the motivations as well as the opportunities to reduce their tax bill legally. We develop a new theoretical framework that analyses the interactions of motivations and opportunities in MNEs’ tax planning strategy. We generate four typologies of corporate tax payers. Our study provides new insights detailing why and how companies plan their tax