Maya Forstater

NB: they are using different methodologies (both valid). The Greens is backward looking. They look at corp accounts in Orbis and divide the tax paid by profit (Data is 2011-2015). OECD is forward looking using @devereux_mike methodology which models depreciation & allowances

The OECD methodology takes account of depreciation of intangible property, such as acquired patents or trademarks, but not expenditure-based R&D tax incentives & IP regimes. Jansky refers to 'tax holidays' as the reason for the difference (he may be meaning the same thing?)

The difference is greatest in the case of Luxembourg where Jansky calculates historical ETR of 2% and OECD calculate forward looking ETR of 24.5% (#taxtwitter what do you think is going on here?)

Effect of int'l groups and profit shifting? D-G method inevitably restrained to the national level and the formal domestic rules, whereas Orbis' cross-country group view emphasises the actual cross-country skews in allocation of profit. For LUX, that makes sense?

But this is not so much looking at skews in allocation of profit allocation but the ETR given the profit reported in each country -- i.e. what is the tax reconciliation between 2% and the statutory tax rate of 29% in Luxembourg etc... ?

That's exactly looking at profit allocation skew? Numerator of the Lux ETR - profit - is *much* larger in the Greens study due to MNCs actually allocating a lot of profit to Lux. With D-G, numerator is imputed as essentially 'normal returns' to a standardised investment.

Sorry, denominator? .. my English.. I think you know what I'm trying to say :)