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The calculations don't take account of how much WHT or tax under CFC regs these tax haven profits attract under current system though. And really, trade tariffs... ?
The data behind the enforcement part of the paper, is thinner, I think, than the data behind the broader CIT-avoidance part. The claim seems to stem from evidence that there are more transfer pricing disputes b't high-tax countries than between high-tax and low-tax countries 1/
but, if these countries have stronger economic links, then wouldn’t there be more TP? And therefore more TP to dispute? It’s a potentially interesting way to look at the issue, but the limited data they have doesn’t allow for controls for economic activity or anything. 2/
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