How Serious Is the Problem of Base Erosion and Profit Shifting?

In recent years, the problem of base erosion and profit shifting (BEPS) by multinational corporations has entered the public consciousness as a potentially important impediment to tax collections. The purpose of this article is to identify the nature of BEPS, consider empirical evidence of its magnitude, and evaluate proposed policy responses. There is considerable evidence that multinational firms arrange their affairs in a tax-sensitive manner, from which it is easy—indeed, perhaps a little too easy—to infer that beps is a serious problem. There are journalistic accounts of apparently spectacular international tax-avoidance schemes used by multinational corporations, though these stories commonly omit or misrepresent important legal and economic elements, making it difficult to know what, if any, conclusion to draw from them. On a serious level, the us Joint Committee on Taxation was recently charged by the us Congress with identifying extreme examples of BEPS among us corporate taxpayers, and produced a report that included six such examples. And statistical studies consistently indicate that multinational corporations report higher profit rates in low-tax jurisdictions than in high-tax jurisdictions, a pattern that is consistent with BEPS