Loss Expectation and Income Shifting

Abstract

This study examines the effects of expected losses on income shifting from various perspectives. Using a set of worldwide multinational corporation (MNC) affiliates, this study first finds empirical evidence of ex ante adjustments of income-shifting strategies by affiliates, supporting the existence of limited flexibility introduced in Hopland et al. (2018, 2019). The study next identifies that loss-expecting affiliates with limited loss carry-forward periods have greater reverse incentives for income shifting than those with unlimited periods because the former must utilize potential losses within a limited period of time. Lastly, according to measurements of the magnitude of income shifting based on expected tax rate differences using the full sample of both profitable and loss affiliates, the methodology applied in traditional studies is found to overestimate the magnitude of income shifting.