Implications of Profit Shifting and "Aggressive" Tax Planning by Multinationals Companies in Ghana

Daniel Anarfi, MSc.

Doctoral thesis

Abstract:

The purpose of the study was to analyse the issues of base erosion and profit shifting by multinational companies operating in Ghana. The current global tax system and the structure and set up of multinationals has created an opportunity for these MNCs to shift profits from one affiliate to the other. Thus, multinational companies shift profit to different affiliate by using techniques such as transfer pricing and debt shifting. The purpose of this dissertation was achieved by providing answers to three (3) major research questions which relates to profit shifting by multinationals in Ghana. The magnitude of profit shifting, the implications of profit shifting on host country and best practical recommendations were the areas the research questions covered. The first research question was about the level of profit shifting by multinational companies in Ghana. In other jurisdictions, particularly in advanced countries, several researchers have found evidence of this situation by measuring the magnitude of profit shifted to or from the host country of the MNC using different approaches. This study also used semi-elasticity of the corporate tax rate differentials to measure the magnitude of profit shifting by multinational companies operating in Ghana. The study employed a modified version of the HR approach to investigating income shifting. The “Hines-Rice” approach, from which several specific models are derived is the most widely used method of measuring profit shifting. By this, a panel regression model was applied on a large panel data for the period of 2006 – 2015 and the Hausman specification test was applied to choose between the random effect model and the fixed effect model. The study results from the analysis show evidence of profit shifting by multinational companies in Ghana in different regression models using pre-tax profit as the dependent variable. The coefficient of the variable tax difference (%) shows -0.305 at a highly significance level giving evidence of profit shifting. This suggest an increase in pre-tax profits of 3.1% if the tax difference to the other affiliate decreases by 10 percentage points. The study also found evidence of profit being shifted out from High Tax country (HTC) to a Low Tax Country (LTC) with a magnitude of -0.357 indicating that a decrease in pre-tax profits of 3.5% of the tax difference to HTC decreases by 10 percentage points. In the financial sector, the coefficient of -0.33 of the tax difference variable suggests that a one percentage point higher of an affiliate tax rate is associated with about 33 percent less reported profits of an affiliate bank as evidence of profit shifting. When the evidence found in this study was compared with previous studies, the results of this study showed a much lower evidence. The study therefore recommends that the country passes specific and general anti-avoidance legislative which have been promulgated to combat activities of multinational companies globally. Also, again this study recommends that a special relevance is placed the OECD’s BEPS project particularly transfer pricing for making policy. Finally, this dissertation recommends that there should be an improvement in the country’s tax administrative system.

Abstract:

The purpose of the study was to analyse the issues of base erosion and profit shifting by multinational companies operating in Ghana. The current global tax system and the structure and set up of multinationals has created an opportunity for these MNCs to shift profits from one affiliate to the other. Thus, multinational companies shift profit to different affiliate by using techniques such as transfer pricing and debt shifting. The purpose of this dissertation was achieved by providing answers to three (3) major research questions which relates to profit shifting by multinationals in Ghana. The magnitude of profit shifting, the implications of profit shifting on host country and best practical recommendations were the areas the research questions covered. The first research question was about the level of profit shifting by multinational companies in Ghana. In other jurisdictions, particularly in advanced countries, several researchers have found evidence of this situation by measuring the magnitude of profit shifted to or from the host country of the MNC using different approaches. This study also used semi-elasticity of the corporate tax rate differentials to measure the magnitude of profit shifting by multinational companies operating in Ghana. The study employed a modified version of the HR approach to investigating income shifting. The “Hines-Rice” approach, from which several specific models are derived is the most widely used method of measuring profit shifting. By this, a panel regression model was applied on a large panel data for the period of 2006 – 2015 and the Hausman specification test was applied to choose between the random effect model and the fixed effect model. The study results from the analysis show evidence of profit shifting by multinational companies in Ghana in different regression models using pre-tax profit as the dependent variable. The coefficient of the variable tax difference (%) shows -0.305 at a highly significance level giving evidence of profit shifting. This suggest an increase in pre-tax profits of 3.1% if the tax difference to the other affiliate decreases by 10 percentage points. The study also found evidence of profit being shifted out from High Tax country (HTC) to a Low Tax Country (LTC) with a magnitude of -0.357 indicating that a decrease in pre-tax profits of 3.5% of the tax difference to HTC decreases by 10 percentage points. In the financial sector, the coefficient of -0.33 of the tax difference variable suggests that a one percentage point higher of an affiliate tax rate is associated with about 33 percent less reported profits of an affiliate bank as evidence of profit shifting. When the evidence found in this study was compared with previous studies, the results of this study showed a much lower evidence. The study therefore recommends that the country passes specific and general anti-avoidance legislative which have been promulgated to combat activities of multinational companies globally. Also, again this study recommends that a special relevance is placed the OECD’s BEPS project particularly transfer pricing for making policy. Finally, this dissertation recommends that there should be an improvement in the country’s tax administrative system.

Keywords

Tax Planning, Profit Shifting, Multinational Companies

Keywords

Profit Shiftine, Tax Planning, Multinational Companies

Language used: English

Date on which the thesis was submitted / produced: 12. 1. 2020

Thesis defence

• Supervisor: prof. Ing. Danuše Nerudová, Ph.D.
• Reader: Leoš Vítek, doc. Ing., Ph.D., Jitka Janová, doc. Ing. Mgr., Daniel Stavárek

Mendel University in Brno

Faculty of Business and Economics

Doctoral programme / field:
Economics and Management / Business Management and Economics