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In an aggregation this kind of thing would tend to cancel out, & only countries that appear on one side predominantly will show up (like Lux) -- this means the ratio isn't picking up 'profit shifting' exactly, but places w more mobile activities & management of intangiables
i.e. the ratio doesn't pick up whether the mobile activities/intangibles are correctly priced and legally compliant, just that they are concentrated there. So then you end up back at the #taxmantra discussionpic.twitter.com/Bme0S3e2wt
And it may not actually tell you the full story if there is another element this ratio does not pick up, such as the operation of CFC rules that may claw back tax on the offshored profits... And would it tell you about impact of any withholding tax on payments of say royalties?
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