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bal sink ofcs jurisdictions in which a disproportional amount of value disappears from the economic system i e the traditional tax havens a five global conduit ofcs jurisdictions through which a disproportional amount of value moves toward sink ofcs i e modern corporate tax havens b our findings debunk the myth of tax havens c as exotic far flung islands that are difficult if not impossible to regulate many offshore financial centers c are highly developed countries with strong regulatory environments javier garcia bernardo jan fichtner frank w takes eelke m heemskerk corpnet university of amsterdam 4 in 2017 the european parliament adopted the corpnet approach into their frameworks for addressing tax havens 7 in 2018 research by gabriel zucman showed that using orbis database connections specifically underestimates the scale of ireland which the zucman tørsløv wier 2018 list showed is the largest conduit ofc in the world 8 9 10 this aside corpnet s conduits and sinks reconcile closely with the most noted academic top ten tax haven lists background edit see also tax haven tax haven lists uncovering offshore financial centers the cayman islands conundrum 4 the lack of an accepted definition for identifying tax havens and even offshore financial centres results in different lists including academic leaders in tax haven research 11 hines 1994 2007 2010 12 13 14 dharmapala 2008 2009 15 and zucman 2015 2018 16 10 9 oecd lists started with 35 locations in 2000 none of which were oecd members 17 but by 2017 only listed trinidad tobago as a tax haven 18 imf ofc lists started with 46 ofcs in june 2000 using qualitative methods 19 refined to 22 ofcs in april 2007 using purely quantitive methods 20 listed the eight major ofcs in 2018 who handle 85 of all flows 21 by 2010 the tax academics considered ofcs as synonymous with tax havens 22 itep lists focus on offshore structures of us s p500 firms and list the netherlands ireland the caribbean and luxembourg in their top five 23 there are traditional tax havens common on all these lists e g some caribbean and channel islands locations which some global regulators have either blacklisted or have issued formal warnings threat of sanctions against unless transparency is increased 24 25 however a key difference between the lists regards the major oecd and eu tax havens or offshore financial centres such as switzerland ireland the netherlands and luxembourg amongst others 26 major regulators like the eu and the oecd don t regard oecd or eu countries as tax havens and point to their transparency and compliance with international regulations 27 28 29 30 academic leaders in tax haven research and other non governmental organizations point to the role of oecd and eu tax havens in tax avoidance from base erosion and profit shifting beps schemes like the double irish the single malt and the dutch sandwich 31 32 33 they regard them as major tax havens in their definitions of tax havens 9 10 corpnet report edit uncovering offshore financial centers example of a corporate global ownership chain 4 a report published in nature in 2017 on the analysis of offshore financial centres called uncovering offshore financial centers conduits and sinks in the global corporate ownership network 4 provided a quantitative and scientific approach to the classification of tax havens 34 35 1 3 the report was the result of a multi year investigation by political economists and computer scientists in the corpnet research group at the university of amsterdam corpnet is a european research council funded group at the university of amsterdam investigating networks of corporate control 2 36 the report used the moody s orbis corporate database 37 to examine 98 million global companies and their 71 million ownership connections using big data computer modelling to identify 5 global conduit ofcs netherlands united kingdom ireland singapore and switzerland these are countries of high financial reputation i e not formally labelled tax havens by oecd eu but who have advanced legal and tax structuring vehicles and spvs that help legally route funds to the 24 tax havens called sink ofcs without incurring tax in the conduit ofc or even tax in the source of funds location where royalty payment schemes can be used 4 5 the work built on methods established in the offshore intensity ratio 38 and in particular the understanding activity relative to the scale of the domestic economy in a country 39 at its crudest level the offshore intensity ratio explains why the countries at the top of global gdp per capita lists are mostly tax havens the eu parliament s policy department on economic and scientific policies included the research in its findings for the eu committee on money laundering tax avoidance and tax evasion pana 40 and by tabulating against existing eu imf fsi list of tax havens showed material gaps in eu understanding of conduits 7 corpnet s top 5 conduits and top 5 sinks are 9 of the 10 largest tax havens identified in 2010 by one of the academic founders of tax haven research james r hines jr hines 2010 list of 10 major tax havens only differs in its omission of the u k which in 2010 had only just reformed its corporate tax system 12 corpnet s top 5 conduits and top 5 sinks closely reconcile with the top 10 major corporate tax havens of other major academic and non governmental organisation tax haven lists other tax academics have incorporated the research into their understanding of tax havens 41 conduit ofcs edit see also tax haven gdp per capita 2018 global innovation property centre gipc legal systems league table patents sub category 42 conduit ofcs are described as having advanced legal and tax systems designed to enable corporations to route funds from high tax locations e g germany to the sink ofcs e g bermuda they tend to have attractive holding company regimes e g no withholding taxes foreign dividends exempt from taxes capital gains reliefs full double tax relief advanced tax treatment of intellectual property regimes and large global networks of bilateral tax treaties 4 43 44 for example corpnet s five major conduit ofcs all have a top ten ranking in the 2018 global innovation property centre gipc ip index 42 45 ip has been described as the raw materials of corporate tax avoidance 46 and the leading corporate tax avoidance vehicle 47 48 conduit ofcs are shown to be dominated by major law firms and global accounting firms who create the lawfully constructed special purpose vehicles spvs and beps tools that make the connections with the sink ofcs by exploiting legislative loopholes such as the double irish and dutch sandwich they advise clients on anticipating future changes e g from oecd beps processes that may need new loopholes e g the single malt arrangement 49 4 other researchers into tax havens have written that professional service firms in the major oecd and eu tax havens write most of their state s relevant taxation and spv related legislation so that they can create and protect loopholes and refer to such jurisdictions as being a captured by their financial services industry 50 51 the legal and tax structuring undertaken by conduit ofcs is considered beyond the trust structuring type work of the traditional tax haven offshore magic circle law firms conduit ofcs need structures that can integrate with bilateral tax treaties involving g20 countries as well as meeting u s gaap sec regulations that u s multinationals one of the largest users of conduit ofcs need to adhere to 52 53 corpnet s top five global conduit ofcs channel 47 of corporate offshore connections and include the following 4 54 netherlands the largest global conduit ofc by total connections with dense links from the eu 28 via the dutch sandwich to the eu sink ofc of luxembourg and the caribbean sink ofc triad of bermuda bvi cayman 55 1 56 united kingdom second largest conduit ofc by total connections with dense links from europe to asia 18 of the 24 sink ofcs are current or past dependencies of the uk see table on sink ofcs 2 57 58 switzerland a major conduit ofc with a very dense network of connections with jersey the fourth largest sink ofc 1 4 singapore the main conduit ofc for asia and densely connected to the two major asian sink ofcs of hong kong and taiwan 4 ireland very dense connections with the us see ireland as a tax haven 1 with very dense connections to sink ofc luxembourg an established backdoor out of the irish tax system 59 60 sink ofcs edit uncovering offshore financial centers list of sink ofcs ordered by value showing u k dependencies 4 sink ofcs cover a broad range of locations from very small countries e g the marshall islands to major global financial centres e g hong kong 4 just because funds reach a sink ofc does not mean that they remain dormant quite the contrary the funds can be invested in assets all over the world but their legal ownership and future gains remain in the sink ofc for example the circa us 1 trillion of us company offshore cash is held in sink ofcs esp the caribbean 61 62 the corpnet report highlighted some interesting aspects of the 24 sink ofcs 4 british virgin islands in terms of connections the bvi was the netherlands of sink ofcs and heavily linked with the conduit ofc united kingdom luxembourg and hong kong could have been considered conduit ofcs but corpnet s research showed they are even bigger sink ofcs i e long term homes for funds for routing funds out of high tax eu countries luxembourg and out of china hong kong jersey remains a unique link with major conduit ofc switzerland because the study could not capture individual jersey trusts it noted that the scale of jersey could still be understated bermuda british virgin islands cayman islands triad these three traditional tax havens are heavily interlinked and starting to present as one large sink ofc taiwan has been a controversial entrant on several tax haven lists and is identified as the 2nd largest asian sink ofc cayman islands the cayman islands are becoming the biggest financial centre for central and latin america 63 malta the report highlights the rise of sink ofc malta as an emerging tax haven inside the eu 64 65 which has been a source of wider media scrutiny 66 mauritius has become a major sink ofc for both se asia especially india and african economies and now ranking 8th overall 67 oecd failings edit of the wider tax environment o rourke thinks the oecd base erosion and profit shifting beps process is very good for ireland if beps sees itself to a conclusion it will be good for ireland feargal o rourke ceo pwc ireland cited architect of the double irish beps tool 68 69 irish times 2015 70 an example of an ip based beps tool is ireland s capital allowances for intangible assets caia tool also known as the green jersey which has an effective tax rate of 0 2 5 apple used the caia or green jersey beps tool in q1 2015 resulting in the leprechaun economics restatement of irish gdp by 34 4 percent ireland has other ip based beps tools ireland as the first oecd nexus compliant kdb 71 and is a supporter of the oecd beps project see box 70 isle of man omitted edit the isle of man the iom was absent from the list of top sink ofcs the iom appears on tax haven lists and ranks 42 on the 2018 financial secrecy index 72 73 the chief minister of the iom howard quayle announced that the corpnet report proved that the iom is not a tax haven 74 75 however corpnet researchers from the university of amsterdam directly replied to howard quayle s article 76 clarifying that while the iom does not appear as a leading sink ofc for corporate tax avoidance it does not mean that individuals personal bank accounts and trusts do not use the iom to avoid taxes and particularly united kingdom vat other commentators have added that the iom is failing as a tax haven and is now too small to appear in major studies like the corpnet research 77 ireland underestimated edit see also corporate tax haven and ireland as a tax haven the corpnet report used legal corporate connections on the orbis database rather than the actual quantum of money as its primary metric of analysis in theory the authors felt that this does not impede the goal of classification and of making relative rankings however it does mean the monetary amount of potential tax avoidance was not calculated 4 the tax haven academic and author of the hidden wealth of nations gabriel zucman used a different quantitative approach zucman focused on macro data of national statistical accounts in theory the total assets in a system should equal the total liabilities by aggregating national account data zucman identified an excess of liabilities over assets implying that the missing assets to balance the equation are hidden in tax havens on this basis in 2015 he estimated that 8 of the world s wealth or us 7 6 trillion was missing in offshore tax havens 78 79 zucman s analysis highlighted the special case of ireland and why the orbis database underestimates ireland s scale as one of the world s largest corporate tax avoidance or beps hubs 80 in 2018 zucman et alia showed that many of ireland s u s multinationals don t appear on orbis e g facebook or only have a small fraction of their data on orbis e g google and apple analysed using quantum of funds not orbis connections zucman showed ireland is one of the largest corporate tax shelters in the world and a route for zucman s estimated loss of 20 in eu corporate tax revenues annually 8 9 10 see also edit corporate tax haven tax haven offshore financial centre financial centre base erosion and profit shifting double irish arrangement notes edit see the table below for the list of the sinks the conduits are netherlands united kingdom switzerland singapore and ireland 1 2 as discussed in the definitions sections of tax havens and of offshore financial centres most tax academics consider the terms as being synonymous and use them inter changeably references edit 1 2 3 4 5 daniel boffey 25 july 2017 netherlands and uk are biggest channels for corporate tax avoidance the guardian archived from the original on 24 may 2018 retrieved 27 april 2019 almost 40 of corporate investments channelled away from authorities and into tax havens travel through the uk or the netherlands according to a study of the ownership structures of 98m firms 1 2 3 hugo millar 31 july 2017 is the u k already the kind of tax haven it claims it won t be bloomberg news archived from the original on 13 june 2018 retrieved 27 april 2019 the u k is the second biggest offshore financial centre for the conduit of money to small sink tax havens like the british virgin islands or cayman islands researchers at university of amsterdam have concluded in a report publisher in nature 1 2 mark buchanan 11 april 2017 tax havens can be surprisingly close to home bloomberg view archived from the original on 17 june 2018 retrieved 10 june 2018 the u k the netherlands and switzerland play bigger roles than t...