Discussion paper

DP16502 Organizational capacity and profit shifting

Good organizational capacity drives productivity and \textit{potential} taxable profits, but may also enable multinationals (MNEs) to more efficiently re-allocate profits across tax jurisdictions, lowering \textit{actual} taxable profits. We show that MNE subsidiaries with better organizational capacity report significantly lower profits and have a higher incidence of bunching around zero reported profitability in high-tax countries. This pattern is not not present in low-tax countries. Further, responsiveness to corporate tax rate changes in terms of profit reporting is driven by firms with good organizational capacity. We show our results are consistent with profit-shifting behavior and rule out key alternative channels.


Bilicka, K and D Scur (2021), ‘DP16502 Organizational capacity and profit shifting‘, CEPR Discussion Paper No. 16502. CEPR Press, Paris & London. https://cepr.org/publications/dp16502