Corporate Tax Statistics - FIRST EDITION - OECD

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Corporate Tax Statistics - FIRST EDITION - OECD
Corporate
Tax Statistics
        FIRST EDITION
Corporate Tax Statistics - FIRST EDITION - OECD
Corporate Tax Statistics
This document and any map included herein are without prejudice
to the status of or sovereignty over any territory, to the delimitation of        CONTENTS
international frontiers and boundaries and to the name of any territory,
city or area.
                                                                                  Introduction                                                 1
The statistical data for Israel are supplied by and under the responsibility
of the relevant Israeli authorities. The use of such data by the OECD is
without prejudice to the status of the Golan Heights, East Jerusalem and          Corporate tax revenues                                       2
Israeli settlements in the West Bank under the terms of international law.
Note by Turkey: The information in this document with reference to “Cyprus”       Statutory corporate income tax rates                         8
relates to the southern part of the Island. There is no single authority
representing both Turkish and Greek Cypriot people on the Island. Turkey
recognises the Turkish Republic of Northern Cyprus (TRNC). Until a lasting        Corporate effective tax rates                              16
and equitable solution is found within the context of the United Nations,
Turkey shall preserve its position concerning the “Cyprus issue”.
                                                                                  Tax incentives for research and development 26
Note by all the European Union Member States of the OECD and the
European Union: The Republic of Cyprus is recognised by all members
of the United Nations with the exception of Turkey. The information               Intellectual property regimes                              33
in this document relates to the area under the effective control of the
Government of the Republic of Cyprus.
                                                                                  References                                                 37

NAMES OF COUNTRIES AND JURISDICTIONS

ALB   Albania                    CUW    Curaçao                    KAZ    Kazakhstan         PRT   Portugal            SWE   Sweden
AND   Andorra                    CYP    Cyprus                     KEN    Kenya              ROU   Romania             CHE   Switzerland
AGO   Angola                     CZE    Czech Republic             KOR    Korea              RUS   Russia              THA   Thailand
AIA   Anguilla                   DNK    Denmark                    LVA    Latvia             RWA   Rwanda              TGO   Togo
ARG   Argentina                  DOM    Dominican Republic         LBR    Liberia            VCT   Saint Vincent and   TKL   Tokelau
AUS   Australia                  COD    DRC                        LIE    Liechtenstein            the Grenadines      TTO   Trinidad and Tobago
AUT   Austria                    EGY    Egypt                      LTU    Lithuania          WSM   Samoa               TUN   Tunisia
BHS   Bahamas                    SLV    El Salvador                LUX    Luxembourg         SAU   Saudi Arabia        TUR   Turkey
BHR   Bahrain                    EST    Estonia                    MAC    Macau, China       SEN   Senegal             TCA   Turks and Caicos
BRB   Barbados                   SWZ    Eswatini                   MYS    Malaysia           SRB   Serbia                    Islands
BEL   Belgium                    FJI    Fiji                       MDV    Maldives           SYC   Seychelles          UGA   Uganda
BLZ   Belize                     FIN    Finland                    MLI    Mali               SGP   Singapore           ARE   United Arab Emirates
BMU   Bermuda                    FRA    France                     MLT    Malta              SVK   Slovak Republic     GBR   United Kingdom
BOL   Bolivia                    GAB    Gabon                      MUS    Mauritius          SVN   Slovenia            USA   United States
BWA   Botswana                   DEU    Germany                    MEX    Mexico             SLB   Solomon Islands     URY   Uruguay
BRA   Brazil                     GHA    Ghana                      MCO    Monaco             ZAF   South Africa        VNM   Viet Nam
VGB   British Virgin Islands     GRC    Greece                     MSR    Montserrat         ESP   Spain
BRN   Brunei Darussalam          GTM    Guatemala                  MAR    Morocco
BGR   Bulgaria                   GGY    Guernsey                   NLD    Netherlands
BFA   Burkina Faso               GUY    Guyana                     NZL    New Zealand
CPV   Cabo Verde                 HND    Honduras                   NER    Niger
CMR   Cameroon                   HKG    Hong Kong, China           NGA    Nigeria
CAN   Canada                     HUN    Hungary                    NOR    Norway
CYM   Cayman Islands             ISL    Iceland                    OMN    Oman
CHL   Chile                      IND    India                      PAN    Panama
CHN   China                      IDN    Indonesia                  PNG    Papua New Guinea
COL   Colombia                   IRL    Ireland                    PRY    Paraguay
COG   Congo                      IMN    Isle of Man                PER    Peru
COK   Cook Islands               ISR    Israel                     PHL    Philippines
CRI   Costa Rica                 ITA    Italy                      POL    Poland
CIV   Côte d’Ivoire              JAM    Jamaica
HRV   Croatia                    JPN    Japan
CUB   Cuba                       JEY    Jersey
Corporate Tax Statistics - FIRST EDITION - OECD
INTRODUCTION . 1

Introduction
The Corporate Tax Statistics database is intended to assist in the study of corporate tax policy and
expand the quality and range of data available for the analysis of base erosion and profit shifting (BEPS).

In developing this first edition of the database, the               analysis of corporate taxation, in general, and of BEPS, in
OECD has worked closely with members of the                         particular.
Inclusive Framework on BEPS (Inclusive Framework)
and other jurisdictions willing to participate in the               The database compiles new data items and statistics
collection and compilation of statistics relevant to                currently collected and stored by the OECD in various
corporate taxation. The 2015 Measuring and Monitoring               existing data sets. The first edition of the database
BEPS, Action 11 report highlighted that the lack of                 contains four main categories of data:
quality data on corporate taxation is a major limitation
to the measurement and monitoring of the scale of                   l corporate tax revenues;
BEPS and the impact of the OECD/G20 BEPS project.                   l statutory corporate income tax rates;
While this database is of interest to policy makers from            l corporate effective tax rates;
the perspective of BEPS, its scope is much broader.                 l tax incentives related to innovation.
Apart from BEPS, corporate tax systems are important
more generally in terms of the revenue that they raise              Future editions will also include an important new
and the incentives for investment and innovation that               data source: aggregated and anonymised statistics of
they create. The Corporate Tax Statistics database brings           data collected under the BEPS Action 13 Country-by-
together a range of valuable information to support the             Country Reports.

  Box 1. CORPORATE TAX STATISTICS

  l   Corporate tax revenues:
      – data are from the OECD’s Global Revenue Statistics
         Database
      – covers 88 jurisdictions from 1965-2016 (for OECD
         members) and 1990-2016 (for non-OECD members)
  l   Statutory corporate income tax rates:
      – covers 94 jurisdictions from 2000-18
  l   Corporate effective tax rates:
      – covers 74 jurisdictions for 2017
  l   Tax incentives for research and development (R&D):
      – data are from the OECD’s R&D Tax Incentive Database
      – covers 47 jurisdictions for 2000-16 (for tax and direct
         government support as a percentage of R&D)
      – covers 44 jurisdictions for 2000-18 (for implied subsidy
         rates for R&D, based on the B-index)
  l   Intellectual property (IP) regimes:
      – data collected by the OECD’s Forum on Harmful Tax
         Practices
      – covers 65 regimes in 41 jurisdictions for 2018
Corporate Tax Statistics - FIRST EDITION - OECD
2 . OECD | CORPORATE TAX STATISTICS

Corporate tax revenues
Data on corporate tax revenues can be used to compare the size of corporate tax revenues across
jurisdictions and to track trends over time. The data in the Corporate Tax Statistics database allow
the comparison of individual jurisdictions as well as average corporate tax revenues across OECD
jurisdictions, 25 Latin American & Caribbean (LAC) jurisdictions, and 21 African jurisdictions1.

   Box 2. CORPORATE TAX REVENUES                                                                KEY INSIGHTS:

   The Corporate Tax Statistics database contains four                                          l   In 2016, the share of corporate tax revenues in total tax
   corporate tax revenues indicators:                                                               revenues was 13.3% on average across the 88 jurisdictions
   l   the level of corporate tax revenues in national currency;                                    in the database, and corporate tax revenues as a
                                                                                                    percentage of GDP was 3.0% on average.
   l   the level of corporate tax revenues in USD;
   l   corporate tax revenues as a percentage of total tax                                      l   The size of corporate tax revenues relative to total tax
       revenues;                                                                                    revenues and relative to GDP varies by groupings of
                                                                                                    jurisdictions. In 2016, corporate tax revenues were a larger
   l   corporate tax revenues as a percentage of gross                                              share of total tax revenues on average in Africa (15.3% in
       domestic product (GDP).                                                                      the 21 jurisdictions) and LAC (15.4% in the 25 jurisdictions)
   The data are from the OECD’s Global Revenue Statistics                                           than the OECD (9%). The average of corporate tax revenues
   Database, which presents detailed, internationally                                               as a share of GDP was the largest in LAC (3.4% in the 25
   comparable data on tax revenues. The classification of                                           jurisdictions), followed by the OECD (2.9%) and Africa
   taxes and methodology is described in detail in the OECD’s                                       (2.8% in the 21 jurisdictions).
   Revenue Statistics Interpretative Guide.
                                                                                                l   In five jurisdictions – Egypt, Kazakhstan, Malaysia, Papua
                                                                                                    New Guinea and the Philippines – corporate tax revenues
                           Corporate tax revenues
                                                                                                    made up more than one-quarter of total tax revenues in
                                                                                                    2016.
                                                                  88
                                                              countries                         l   Corporate tax revenues are driven by the economic cycle.
                                                            and growing...
                                                                                                    For the period 2000-16, average corporate tax revenues as
                                                                                                    a percentage of GDP reached their peak in 2007 (3.6%) and
             CIT revenues as a share of total tax revenues                                          declined in 2009 and 2010 (3.2% and 3.1% respectively),
                                                                                                    reflecting the impact of the global financial and economic
                                                                                                    crisis.
          12.0%                                               13.3%                             l   For jurisdictions where the exploitation of natural resources
              2000                                                2016                              is a significant part of the economy, changes in commodity
                                                                                                    prices can have a significant effect on corporate tax
                  CIT revenues as a percentage of GDP                                               revenues. From 2015 to 2016, the share of corporate tax in
                                                                                                    total tax decreased by more than five percentage points in
                                                                                                    two jurisdictions, the Democratic Republic of Congo (from
            2.7%                                               3.0%                                 20.6% to 14.5%) and Trinidad and Tobago (from 44.0% to
                                                                                                    23.4%). In both of these jurisdictions, the drop was driven
              2000                                                2016                              by a decline in commodity prices.

1. The Global Revenue Statistics Database covers 92 jurisdictions in 2018. Data on corporate tax revenues is available for 88 of these jurisdictions. In addition to the OECD, Latin
America & Caribbean jurisdictions, and African jurisdictions, the Global Revenue Statistics Database also contains data on Asian and Pacific jurisdictions, but the number of
jurisdictions is not sufficiently large for the calculation of meaningful averages for the Asia and Pacific Region.
Corporate Tax Statistics - FIRST EDITION - OECD
CORPORATE TAX REVENUES . 3

 FIGURE 1: Average corporate tax revenues as a percentage of total tax and as a percentage of GDP
                               18%                                                                                                                                                                      4%

                               16%

                               14%
                                                                                                                                                                                                        3%

                               12%
Percentage of total taxation

                                                                                                                                                                                                             Percentage of GDP
                               10%
                                                                                                                                                                                                        2%
                               8%

                               6%

                                                                                                                                                                                                        1%
                               4%
                                        Note: These averages are unweighted. The number of jurisdictions used to calculate the
                                        averages shown in this figure grew from 77 in 2000 to 88 in 2016. Therefore, the averages
                               2%       shown in the early years are not strictly comparable with the averages shown in the later years.
                                        Source: Data from the Global Revenue Statistics Database, http://oe.cd/global-rev-stats-database          Percentage of total taxation      Percentage of GDP
                               0%                                                                                                                                                                       0%
                                       2000      2001      2002      2003      2004      2005      2006      2007      2008      2009      2010     2011      2012      2013     2014   2015     2016

  TRENDS IN CORPORATE TAX REVENUES                                                                                           Between 2000 and 2016, the trend for both indicators is
                                                                                                                             very similar. When measured both as a percentage of
 Data from the OECD’s Corporate Tax Statistics database                                                                      total tax revenues and as a percentage of GDP, corporate
 reveal that there was a slight increase in both the                                                                         tax revenues reached their peak in 2007 and then
 average of corporate income tax (CIT) revenues as                                                                           dipped in 2009 and 2010, reflecting the impact of the
 a share of total tax revenues and as a share of GDP                                                                         global financial and economic crisis. While average CIT
 between 2000 and 2016 across the 88 jurisdictions                                                                           revenues recovered after 2010, the unweighted averages
 for which data are available (see Figure 1).2 Average                                                                       declined in each of the last three years for which data
 corporate tax revenues as a share of total tax revenues                                                                     across all 88 jurisdictions are available (2014, 2015 and
 increased from 12.0% in 2000 to 13.3% in 2016, and                                                                          2016). Some of the recent drop can be explained by a
 average CIT revenues as a percentage of GDP increased                                                                       drop in commodity prices, which has decreased CIT
 from 2.7% in 2000 to 3.0% in 2016.                                                                                          revenues particularly in resource-intensive economies.

                                     Corporate tax revenues are particularly important                                              Corporate tax revenues as a share of total tax in 2016
                                                  in developing economies
                                     (CIT revenues as a share of total tax revenues in 2016)
                                       AFRICA (21): 15.3%                        LAC (25): 15.4%

                                                                                                                                25%
                                                                                                                                                      Corporate tax revenues made up more than
                                                                                                                                                      one-quarter of total tax revenues in 2016:
                                                                                                                                  OR MORE             Egypt, Kazakhstan, Malaysia, Papua New
                                                                                                                                                      Guinea, and the Philippines
                                                               OECD: 9.0%

                                                                                                                                   5%
                                                                                                                                   OR LESS
                                                                                                                                                      Corporate tax revenues made up less than
                                                                                                                                                      5% of total tax revenues in 2016: Bahamas,
                                                                                                                                                      France, Iceland, Slovenia, and Tokelau

 2. The latest available tax revenue data available across all jurisdictions in the database are for 2016, although there are 2017 data available for some jurisdictions in the
 Global Revenue Statistics database.
Corporate Tax Statistics - FIRST EDITION - OECD
4 . OECD | CORPORATE TAX STATISTICS

FIGURE 2: Corporate tax revenues as a percentage of total tax revenues, 2016
MYS
 EGY
PNG
 KAZ
 PHL
 COL
 SGP
 THA
  PER
 TTO
GTM
COG
    FJI
MEX
 CHL
 GUY
  IDN
ESW
 NER
HND
 TGO
  BFA
 BOL
CMR
MAR
  BLZ
 AUS
 ZAF
RWA
  SLV
 NZL
DOM
 CUB
  MLI
  PRY
COD
GHA
MUS
 KOR
 COK
 KEN
 PAN
 LUX
 CPV
  JPN
 SGB
   IRL
 CHE
  CZE
 URY
 SVK
   CRI
CAN
NOR
   CIV
 JAM
   ISR
 BRA
WSM
 ARG
  PRT
 NLD
 SEN
 GBR
 BRB
  BEL
 USA
  ESP
UGA
 TUR
 GRC
SWE
HUN
DNK
 AUT
  LVA
 POL
 TUN
  LTU                                                                                                                                                                Revenues
 DEU
  EST                                                                                                                                                                LAC average (25)
   FIN
   ITA                                                                                                                                                               Africa average (21)
   ISL
  FRA                                                                                                                                                                OECD average
 SVN
  TKL                                                                                         Source: Data from the Global Revenue Statistics Database, http://oe.cd/global-rev-stats-database
 BHS
      0%               5%                 10%                 15%                20%                 25%                   30%                    35%                   40%                      45%

Note: The statistical data for Israel are supplied by and under the responsibility of the relevant Israeli authorities. The use of such data by the OECD is without prejudice to the
status of the Golan Heights, East Jerusalem and Israeli settlements in the West Bank under the terms of international law.
Corporate Tax Statistics - FIRST EDITION - OECD
CORPORATE TAX REVENUES . 5

The averages mask substantial differences across                 l the degree to which firms in a jurisdiction are
jurisdictions. In 2016, jurisdictions differed considerably        incorporated;
in the portion of total tax revenues raised by the
                                                                 l the breadth of the corporate income tax base;
corporate income tax (see Figure 2). In Egypt,
Kazakhstan, Malaysia, Papua New Guinea and the                   l the current stage of the economic cycle and the
Philippines, CIT revenue accounted for more than 25%               degree of cyclicality of the corporate tax system
of total tax revenue. In Malaysia, it accounted for more           (for example, from the generosity of loss offset
than 40%. In contrast, some jurisdictions – such as                provisions);
the Bahamas, Tokelau,3 France, Iceland and Slovenia
                                                                 l the extent of reliance on other types of taxation, such
– raised less than 5% of total tax revenue in the form
                                                                   as taxes on personal income and on consumption;
of corporate income tax. The average revenue share of
corporate tax in 2016 also varied across the OECD and            l the extent of reliance on tax revenues from the
the regional groupings (Latin American & the Caribbean             exploitation of natural resources;
and Africa). In 2016, the OECD average was the lowest, at
                                                                 l other instruments to postpone the taxation of earned
9.0%, compared to the African (21) average (15.3%) and
                                                                   profits.
the LAC (25) average (15.4%).
                                                                 Generally, differences in corporate tax revenues as a
Some of the variation in the share of corporate income           share of total tax revenues should not be interpreted
tax in total tax revenues results from differences               as being related to BEPS behaviour, since many other
in statutory corporate tax rates, which also vary                factors are more significant, although profit shifting may
considerably across jurisdictions. In addition, this             have some effects at the margin.
variation can be explained by institutional and
jurisdiction-specific factors, including:

3. The Bahamas and Tokelau do not levy a corporate income tax.
Corporate Tax Statistics - FIRST EDITION - OECD
6 . OECD | CORPORATE TAX STATISTICS

FIGURE 3: Corporate tax revenues as a percentage of GDP, 2016

CUB
MYS
TTO
  FJI
 NZL
 BLZ
 EGY
 COL
GUY
 LUX
 ZAF
AUS
 BOL
MAR
THA
 PHL
 CHL
TGO
 KAZ
NOR
HND
COK
 PER
 CZE
 JPN
KOR
MEX
 SVK
COG
 BEL
PNG
CAN
NLD
 BFA
 SGP
 BRA
 CHE
  ISR
 PRT
 URY
ESW
ARG
 SLV
MUS
 SLB
GTM
SWE
 GBR
JAM
  IRL
DNK
 NER
 BRB
RWA
 PRY
 ISL
GHA
GRC
CMR
 MLI
AUT
  CRI
HUN
WSM
 IDN
 CPV
 KEN
 ESP
  FIN
 ITA
DOM
 PAN
 FRA
 USA
 DEU
 SEN
 POL
  CIV
  EST                                                                                                                                  Revenues
 LVA
 TUR                                                                                                                                   LAC average (25)
 LTU
 TUN                                                                                                                                   Africa average (21)
 SVN
COD                                                                                                                                    OECD average
UGA
  TKL                                                           Source: Data from the Global Revenue Statistics Database, http://oe.cd/global-rev-stats-database
 BHS
        0%         1%                 2%            3%                     4%                           5%                           6%                            7%
Corporate Tax Statistics - FIRST EDITION - OECD
CORPORATE TAX REVENUES . 7

CORPORATE TAX REVENUES AS A SHARE OF GDP

Corporate tax revenues as a percentage of GDP also          tax revenue share of total tax revenue differs, such
vary among jurisdictions. In 2016, the ratio of corporate   as differences in statutory corporate tax rates and
tax revenues to GDP for a majority of jurisdictions fell    differences in the degree to which firms in a given
between 2% and 5% of GDP (see Figure 3). For a few          jurisdiction are incorporated. In addition, the total level
jurisdictions, corporate tax revenues accounted for a       of taxation as a share of GDP plays a role. For example,
larger percentage of GDP; they are more than 5% of GDP      for the 21 African jurisdictions, the relatively high
in Malaysia, Cuba, and Trinidad and Tobago. In contrast,    average revenue share of CIT compared to the relatively
they are less than 2% of GDP in 12 jurisdictions.           low average of CIT as a percentage of GDP reflects the
                                                            low amount of total tax raised as a percentage of GDP
In 2016, the OECD and African (21) averages were almost     (average of 18.2%). Total tax revenue as a percentage of
identical, at 2.8% of GDP, whereas the LAC (25) average     GDP is higher for the 25 LAC jurisdictions (average of
was higher (3.4%).                                          22.7%) and OECD jurisdictions (average of 34.0%). Across
                                                            jurisdictions in the database, low tax-to-GDP ratios may
The reasons for the variation across jurisdictions in       reflect policy choices as well as difficulties in domestic
corporate tax revenues as a percentage of GDP are           resource mobilisation.
similar to those that account for why the corporate

                    In 2016, average corporate tax revenues as a percentage of GDP were highest in
                    the LAC (25) region at 3.4%. The OECD and African (21) averages were 2.8%.
Corporate Tax Statistics - FIRST EDITION - OECD
8 . OECD | CORPORATE TAX STATISTICS

Statutory corporate income tax rates
Statutory corporate income tax rates show the headline tax rate faced by corporations and can
be used to compare the standard tax rate on corporations across jurisdictions and over time. As
statutory tax rates measure the marginal tax that would be paid on an additional unit of income, in
the absence of other provisions in the tax code, they are often used in studies of BEPS to measure
the incentive that firms have to shift income between jurisdictions.

Standard statutory tax rates, however, do not give                      base to which the rate applies. Further information,
a full picture of the tax rates faced by corporations                   such as the data on effective corporate tax rates and
in a given jurisdiction. The standard corporate tax                     intellectual property (IP) regimes in the Corporate Tax
rate does not reflect any special regimes or rates                      Statistics database, is needed to form a more complete
targeted to certain industries or income types, nor                     picture of the tax burden on corporations across
does it take into account the breadth of the corporate                  jurisdictions.

KEY INSIGHTS:

l   Statutory tax rates have been decreasing on average over the        l   Comparing 2000 and 2018, six jurisdictions – Bulgaria,
    last two decades, although considerable variation among                 Germany, Guernsey, Jersey, the Isle of Man and Paraguay –
    jurisdictions remains. The average combined (central and                decreased their statutory tax rates by 20 percentage points
    sub-central government) statutory tax rates for all covered             or more. During this time, Guernsey, Jersey and the Isle
    jurisdictions was 21.4% in 2018, compared to 21.7% in 2017              of Man eliminated preferential regimes and reduced their
    and 28.6% in 2000.                                                      standard statutory tax rates to zero.

l   Of the 94 jurisdictions covered, 18 had statutory tax rates         l   From 2017 to 2018, the combined statutory tax rate
    equal to or above 30% in 2018, with India having the                    decreased in ten jurisdictions and increased in six (Canada,
    highest statutory tax rate at 48.3%, which includes a tax on            India, Korea, Latvia, Portugal, Turkey).
    distributed dividends.
                                                                        l   The jurisdictions with the largest decreases in the combined
l   In 2018, 12 jurisdictions had no corporate tax regime or                corporate tax rate between 2017 and 2018 were France (an
    a statutory income tax rate of zero. Only one jurisdiction,             almost 10 percentage point decrease) and the United States
    Hungary (9%), had a positive statutory tax rate less than               (a decrease of 13.07 percentage points). France repealed
    10%. Hungary, however, also has a local business tax,                   an exceptional surtax on corporate profits that had been
    which does not use corporate profits as its base. This is not           in place in 2017, and the United States lowered its central
    included in Hungary’s statutory tax rate, but it does mean              government corporate tax rate by 14 percentage points. The
    that businesses in Hungary are subject to a higher level of tax         jurisdiction with the largest increase was Latvia (an increase
    than its statutory tax rate reflects.                                   of 5 percentage points), which transitioned at the same time
                                                                            to a CIT system where tax is only imposed on distributed
l   Comparing statutory tax rates between 2000 and 2018, 76                 earnings.
    jurisdictions had lower tax rates in 2018, while 12 jurisdictions
    had the same tax rate, and 6 had higher tax rates (Andorra;
    Chile; Hong Kong, China; India; the Maldives; Oman).
                                                                            The average statutory tax rate fell by   7.2 percentage points
l   The largest increases between 2000 and 2018 were in
                                                                               from   28.6   %
                                                                                       in 2000...
    Andorra and Chile (both at 10 percentage points) and the
    Maldives (15 percentage points). Andorra and the Maldives                                                            21.4%
                                                                                                                     ...to
                                                                                                                     in 2018
    did not have a corporate tax regime and introduced one
    during this time period.
STATUTORY CORPORATE INCOME TAX RATES . 9

FIGURE 4: Statutory corporate income tax rates, 2018
  IND
 MLT
COD
 FRA
 BRA
MCO
 SEN
  PRT
  SYC
 SVG
NGA
MSR
MEX
 KEN
 GAB
 AUS
 ARG
AGO
 DEU
  JPN
  BEL
  PER
 GRC
 ZAF
 NZL
   ITA
 KOR
 BFA
CAN
 LUX
 USA
 URY
PAN
 NLD
  LBR
 JAM
  IDN
  ESP
   CIV
CHN
 CHL
 BRB
 AUT
MYS
NOR
   ISR
 EGY
 TUR
SWE
DNK                                                                        When comparing 2000 and 2018,
CUW
BWA                                                                         statutory corporate tax rates:
 CHE
 SVK
VNM
 THA
 RUS                                                                                   FELL in

                                                                                      76
 LVA
    ISL
   FIN
  EST
 SVN                                                                                jurisdictions
 POL
 GBR
  CZE
 BRN
 HRV
 SGP
HKG                                                                                  WERE THE
ROM                                                                                   SAME in

                                                                                      12
  SRB
OMN
MUS
MDV                                                                                 jurisdictions
 LTU
    LIE
   IRL
MAC
 PRY
 BGR
AND
HUN                                                                                INCREASED in

                                                                                          6
 VGB
 TCA
 SAU
   JEY
 IMN                                                                                jurisdictions
GGY
CYM
BMU
 BHS
 BHR
 ARE
  AIA
      0%      5%         10%         15%         20%   25%   30%         35%        40%          45%         50%
10 . OECD | CORPORATE TAX STATISTICS

                          Box 3. STATUTORY CORPORATE INCOME TAX RATES

                          The Corporate Tax Statistics database reports statutory tax             The standard rate, that is not targeted at any particular
                          rates for resident corporations at the:                                 industries or income type, is reported. The top marginal rate
                                                                                                  is reported if a jurisdiction has a progressive corporate tax
                          l    central government level;
                                                                                                  system. Other special corporate taxes that are levied on a base
                          l    central government level exclusive of any surtaxes;                other than corporate profits are not included.
                          l    central government level less deductions for subnational taxes;
                                                                                                  The statutory tax rate data presented in this report refer to
                          l    sub-central government level;                                      combined statutory corporate tax rates, unless otherwise
                                                                                                  noted.
                          l    combined (central and sub-central) government level.

    STATUTORY CORPORATE TAX RATES SINCE 2000

    The distribution of statutory tax rates changed                                               Most of the downward movement in tax rates between
    significantly between 2000 and 2018 (see Figure 5).                                           2000 and 2018 was to statutory tax rates equal to or
    In 2000, 12 jurisdictions had tax rates greater than or                                       greater than 10% and less than 30%. The number of
    equal to 40%, while only 1 jurisdiction (India) had a rate                                    jurisdictions with tax rates equal to or greater than 20%
    exceeding 40% in 2018, and that rate only applies to                                          and less than 30% jumped from 20 jurisdictions to
    distributed earnings. Over three-fifths (58 jurisdictions)                                    43 jurisdictions, and the number of jurisdictions with
    of the 94 jurisdictions in the database had statutory tax                                     tax rates equal to or greater than 10% and less than 20%
    rates greater than or equal to 30% in 2000 compared to                                        more than tripled, from 6 to 20 jurisdictions.
    less than one-fifth (18 jurisdictions) in 2018.

    FIGURE 5: Changing distribution of statutory corporate tax rates
                          50

                                                                                                                                                                  2000
                          45
                                                                                                                                                                  2018

                          40

                          35

                          30
Number of jurisdictions

                           25

                          20

                          15

                          10

                           5

                           0
STATUTORY CORPORATE INCOME TAX RATES . 11

                  The average statutory corporate tax rate declined more significantly in the OECD
                  than in the regional groupings (a decline of 8.5 percentage points, from 32.2%
                  in 2000 to 23.7% in 2018).

Despite the general downward movement in tax rates             regimes that were not compliant with the BEPS Action
during this period, the number of jurisdictions with very      5 minimum standard, and the Maldives is also in the
low tax rates of less than 10% remained fairly stable          process of amending or abolishing such regimes.)
between 2000 and 2018. There were 10 jurisdictions
with tax rates less than 10% in 2000, and 13 below that        CORPORATE TAX RATE TRENDS ACROSS REGIONS
threshold in 2018.
                                                               Since 2000, average statutory tax rates have declined
There has, however, been some movement of jurisdictions        across OECD member states and three regional groupings
into and out of this category, and these movements             of jurisdictions: 14 African jurisdictions, 17 Asian
illustrate how headline statutory tax rates do not give a      jurisdictions and 19 LAC jurisdictions (see Figure 6).4
complete picture of the tax rate in a jurisdiction. Between
2005 and 2009, the British Virgin Islands, Guernsey, Jersey    The grouping with the most significant decline has been
and the Isle of Man all moved from standard statutory          the OECD (a decline of 8.5 percentage points, from 32.2%
corporate tax rates above 10% to zero corporate tax            in 2000 to 23.7% in 2018) followed by the African (14)
rates. In all of these cases, however, before changing their   average with a decline of 7.3 percentage points, from
standard corporate tax rate to zero, they had operated         34.4% in 2000 to 27.1% in 2018. While the averages have
broadly applicable special regimes that resulted in very       fallen for each grouping over this period, there remains
low tax rates for qualifying companies. Meanwhile,             a significant level of difference between the average for
Andorra and the Maldives instituted corporate tax regimes      each group: the average corporate tax rate for Africa
and moved from zero rates to positive tax rates (10%           (14) was 27.1% in 2018, compared to 23.7% for the OECD,
in Andorra beginning in 2012 and 15% in the Maldives           18.4% for Asia (17) and 17.9% for LAC (19).
beginning in 2011). However, they also introduced
preferential regimes as part of their corporate tax systems    4. As the sample of jurisdictions for which tax revenue data are available and the
                                                               sample of jurisdictions for which statutory corporate tax rate data are available are
that offered lower rates to qualifying companies. (Andorra     not the same, the average corporate tax revenue and statutory tax rate data for the
has recently amended or abolished its preferential             different regional groups should not be directly compared.
12 . OECD | CORPORATE TAX STATISTICS

FIGURE 6: Average statutory corporate income tax rates by region
40%
                                                                                         Overall          Africa (14)          Asia (17)          LAC (19)          OECD

35%

30%

25%

20%

      Note: For readability purposes, the Y-axis value has been positioned to start at 15%
15%
      2000   2001     2002     2003     2004     2005     2006     2007     2008     2009     2010   2011       2012     2013     2014     2015    2016      2017   2018

      Percentage of jurisdictions with statutory corporate tax rates greater than, or equal to, 30%

                                       2000                                      2005                                         2010
40%
                                                                                         Overall          Africa (14)          Asia (13)          LAC (13)          OECD
                                62%                                        47%                                          29%

35%

                                                            2015                                     2018

30%
                                                     23%                                           19%

25%

                       Excluding jurisdictions with a zero statutory tax rate, the overall average
20%
                       statutory tax rate declined from 31.7% to 24.0% from 2000 to 2018.

15%
      2000    2001     2002     2003     2004     2005     2006     2007     2008     2009    2010       2011   2012      2013     2014    2015     2016     2017   2018
15%                                                                                                    STATUTORY CORPORATE INCOME TAX RATES . 13
      2000   2001     2002     2003     2004     2005     2006      2007     2008     2009    2010   2011    2012    2013   2014    2015    2016      2017   2018

FIGURE 7: Average statutory corporate income tax rates by region excluding zero-rate jurisdictions
40%
                                                                                         Overall       Africa (14)      Asia (13)          LAC (13)          OECD

35%

30%

25%

20%

      Note: For readability purposes, the Y-axis value has been positioned to start at 15%
15%
      2000    2001     2002     2003     2004     2005     2006     2007     2008     2009    2010   2011    2012    2013   2014    2015     2016     2017   2018

The inclusion of jurisdictions with corporate tax rates                                 the time period; meanwhile, the average statutory
of zero affects the average tax rate and has larger                                     tax rate for the full group of 17 Asian jurisdictions is
effects on some regions than on others, since zero-                                     5-10 percentage points lower per year than the average
rate jurisdictions are not evenly distributed among the                                 statutory tax rate for OECD jurisdictions.
different groups (see Figure 7).
                                                                                        Excluding zero-rate jurisdictions results in the most
Excluding zero-rate jurisdictions raises the overall average                            striking difference in the LAC region. In 2018, the
statutory tax rate by about 3.6 percentage points per year,                             average statutory tax rate across all 19 LAC jurisdictions
while the general downward trend remains the same.                                      (17.9%) was 8.3 percentage points lower than the average
From 2000 to 2018, the overall average statutory rate for                               statutory tax rate for the 13 LAC jurisdictions with
non-zero rate jurisdictions declined from 31.7% to 24.0%.                               positive CIT rates (26.2%). With the exclusion of zero-
                                                                                        rate jurisdictions, the LAC (13) average is higher than
The effect of excluding zero-rate jurisdictions varies                                  the OECD average and is second only to the average
by grouping. There are no zero-rate jurisdictions in                                    statutory rate for African (13) jurisdictions.
the OECD or Africa (14), and so the average statutory
                                                                                             In 2018, the African (14) region had the highest average
tax rates of these groupings are not affected. However,
                                                                                                       statutory corporate tax rate at 27.1%.
4 of the 17 Asian jurisdictions and 6 of the 19 LAC
jurisdictions have or had statutory corporate tax rates
set at zero; therefore, the average statutory tax rates
of the 13 Asian jurisdictions with positive statutory tax                                                                            Africa (14)
rates and the 13 LAC jurisdictions with positive statutory
tax rates are higher than the averages for those regions
when all jurisdictions are included. The average
                                                                                                                                    27.1%
statutory rates of non-zero-rate Asian (13) jurisdictions
and the OECD jurisdictions are extremely similar over
14 . OECD | CORPORATE TAX STATISTICS

THE STANDARD STATUTORY CORPORATE TAX RATE IS NOT THE ONLY CORPORATE TAX RATE

Standard statutory tax rates provide a snapshot of        Jurisdictions with broadly applicable tax regimes available
the corporate tax rate in a jurisdiction. However,        to international companies
jurisdictions may have multiple tax rates with the
applicable tax rate depending on the characteristics of   Preferential tax regimes are especially important in
the corporation and the income.                           understanding how standard statutory tax rates do not
                                                          always capture the incentives that may exist to engage
l Some jurisdictions operate preferential tax regimes
                                                          in BEPS behaviours. In particular, some jurisdictions offer
  with lower rates offered to certain corporations or     or have offered very low rates through regimes that are
  income types.                                           available to international companies with relatively few
                                                          restrictions, while maintaining high standard statutory
l Some jurisdictions tax retained and distributed
                                                          tax rates.
  earnings at different rates.

l Some jurisdictions impose different tax rates on        For example, a number of jurisdictions offer or have
  certain industries.                                     offered International Business Companies regimes.
                                                          Companies qualifying for these regimes pay a reduced
l Some jurisdictions have progressive rate structures     rate of tax relative to the standard statutory CIT rate.
  or different regimes for small and medium sized         While the standard statutory tax rate may be quite high
  companies.                                              in these jurisdictions, qualifying international business
                                                          companies are typically exempt from tax or pay a tax
l Some jurisdictions impose different tax rates on non-
                                                          rate of only a few percentage points. There are also other
  resident companies than on resident companies.
                                                          cases, like Malta, which offers a refund of up to six-
l Some jurisdictions impose lower tax rates in special    sevenths of corporate income taxes to both resident and
  or designated economic zones.                           non-resident investors through its imputation system.
STATUTORY CORPORATE INCOME TAX RATES . 15

FIGURE 8: Tax rates of broadly applicable tax regimes
available to international companies

         Malta

 St Vincent and
the Grenadines

    Montserrat

    Seychelles

     Barbados

      Curaçao

      Maldives

                                                                           Taxes on distributed earnings
     Mauritius

                                                                           Another way in which standard statutory tax rates
                                                Standard corporate         may not reflect the rates imposed on companies is if
      Andorra                                   income tax rate
                                                                           jurisdictions tax distributed earnings in addition to (or
                                                Reduced rate
                                                                           instead of) a corporate income tax on all profits.
                  0%   5%   10%   15%   20%   25%   30%   35%        40%
                                                                           In some jurisdictions, there is a tax on all corporate
Figure 8 shows the standard CIT rate in 2018 as well as a                  profits when they are earned and an additional tax on
reduced CIT rate available through a special regime (or                    any earnings that are distributed. This is the case in India,
through an imputation system, in the case of Malta), for                   for example, where corporate profits, whether retained or
jurisdictions which have been identified as implementing                   distributed, are taxed at a rate of 34.9%, and an additional
regimes, with broad application, that offer low rates to                   tax on dividend distributions raises the total tax rate on
international companies. The jurisdictions shown in                        distributed profits to 48.3%.
Figure 8 are only those for which statutory CIT rate data is
available in the Corporate Tax Statistics database; there are              In other jurisdictions, there is no tax on profits when
similar regimes around the world in other jurisdictions.                   they are earned, and corporate tax is only imposed
Since jurisdictions may offer multiple special regimes                     when profits are distributed. This is the case in both
and the exact tax rate may depend on the companies’                        Estonia and Latvia, which both tax distributed profits
circumstances, the reduced rates shown are representative.                 at 20% and impose no tax on retained earnings. While
                                                                           20% is reported for both countries in the Corporate Tax
Except for the Maltese imputation system, which is                         Statistics database, the rate faced by corporations in
not in the scope of the BEPS project, all of the regimes                   these jurisdictions could be much lower and will depend
shown were amended or abolished during 2018 or are in                      on the proportion of profits that are distributed. In the
the process or being amended or abolished to be aligned                    case of both of these jurisdictions, where a corporation
with the BEPS Action 5 minimum standard. These                             retains all profits and does not pay any dividends in
changes should greatly diminish the incentives these                       a given period, it will not be subject to any corporate
regimes provide for BEPS behaviour.                                        income tax.
16 . OECD | CORPORATE TAX STATISTICS

Corporate effective tax rates
Variations in the definition of corporate tax bases across jurisdictions can have a significant impact
on the tax liability associated with a given investment. For instance, corporate tax systems differ
across jurisdictions with regard to several important features, such as fiscal depreciation rules as
well as other allowances and deductions. To capture the effects of these provisions on corporate tax
bases and tax liabilities, it is necessary to go beyond a comparison of statutory tax rates.

It is well understood that cross-jurisdiction
                                                              Box 4. CORPORATE EFFECTIVE TAX RATES
competitiveness is not solely driven by the tax costs
associated with an investment; many other factors, such       The Corporate Tax Statistics database contains four forward-
as the quality of the workforce, infrastructure and the       looking tax policy indicators reflecting tax rules as of 1 July
legal environment, affect profitability and are likely to     2017:
have significant impacts on investment decisions. In
measuring the competitiveness of jurisdictions, however,      l   the effective marginal tax rate (EMTR);
effective tax rates (ETRs) provide a more accurate            l   the effective average tax rate (EATR);
picture of the effects of corporate tax systems on the
actual tax liabilities faced by companies than statutory      l   the cost of capital;
tax rates.                                                    l   the net present value of capital allowances as a share of
                                                                  the initial investment.
The Corporate Tax Statistics database presents “forward-
looking” ETRs, which are synthetic tax policy indicators      All four tax policy indicators are calculated by applying
calculated using information about specific tax policy        jurisdiction-specific tax rules to a prospective, hypothetical
rules. Unlike “backward-looking” ETRs, they do not            investment project. Calculations are undertaken separately
incorporate any information about firms’ actual tax           for investments in different asset types and by sources
payments. As described in more detail in Box 6, the ETRs      of financing (i.e. debt and equity). Composite tax policy
reported in the first edition of Corporate Tax Statistics     indicators are computed by weighting over assets and
focus on the effects of fiscal depreciation and several       sources of finance. In addition, more disaggregated results
related provisions (e.g., allowances for corporate equity,    are also reported in the Corporate Tax Statistics database.
half-year conventions, inventory valuation methods).          The tax policy indicators are calculated for three different
While this includes fiscal depreciation rules for             macroeconomic scenarios. Unless noted, the results
intangible property, such as acquired patents or trade-       reported in this report refer to composite effective tax
marks, for example, the effects of expenditure-based          rates based on the macroeconomic scenario with a 3% real
R&D tax incentives and intellectual property (IP) regimes     interest rate and 1% inflation.
are not accounted for. It is intended that the effects of
R&D tax incentives and IP regimes will be included in
                                                             Largest statutory tax rate reductions due to fiscal acceleration
the dataset in the future.
                                                                                 (percentage points, 2017)

In addition, it should be noted that the ETRs reflect
tax rules as of 1 July 2017, thus not accounting for the
effects of the US Tax Cuts and Jobs Act, which entered
into force in 2018. Recent studies applying similar               USA                 India          Papua New Guinea         Belgium
forward-looking ETR methodologies suggest that this               4.8                  3.8                  3.8                 3.6
                                                             percentage points   percentage points     percentage points   percentage points
reform package has significantly reduced the ETRs in the
United States.
                                                                                 If capital allowances are more generous than
                                                                                 economic depreciation, fiscal depreciation is
                                                                                 accelerated. Fiscal acceleration can be measured
                                                                                 by comparing the EATR to the statutory rate.
CORPORATE EFFECTIVE TAX RATES . 17

KEY INSIGHTS:

l   Of the 74 jurisdictions covered in 2017, 55 provide accelerated       l   Effective marginal tax rates (EMTRs) are the lowest in
    depreciation, meaning that investments in these jurisdictions             jurisdictions with the most accelerated fiscal depreciation
    are subject to EATRs below their statutory tax rates. Among               rules, including two large economies with comparatively
    those jurisdictions, the average reduction of the statutory               high statutory tax rates: India and the United States. In
    tax rate was 1.8 percentage points; in 2017, the largest                  addition, jurisdictions with an ACE also have considerably
    effects were observed in the United States (4.8 percentage                lower EMTRs.
    points), India (3.8 percentage points), Papua New Guinea
    (3.8 percentage points) and Belgium (3.6 percentage points).          l   Disaggregating the results to the asset level reveals that fiscal
                                                                              acceleration is strongest for investments in buildings and
l   In contrast, fiscal depreciation was decelerated in 11 juris­             machinery. For these two asset categories, the average EATR
    dictions, leading to EATRs above the statutory tax rate. Among            across jurisdictions is 19.3% and 19.6%, considerably lower
    those jurisdictions, the average increase of the statutory tax rate       than the average composite EATR (20.5%).
    was 2.4 percentage points; the largest increases were observed
    in Costa Rica (8 percentage points), Chile (6.8 percentage points)    l   Investments in intangibles are subject to very different
    and Botswana (5.3 percentage points).                                     ETRs due to significant variation in tax treatment across
                                                                              jurisdictions. In particular, intangibles are non-depreciable
l   Among all 74 jurisdictions, only 5 jurisdictions had an                   in Botswana, Chile and Costa Rica, leading to strongly
    allowance for corporate equity (ACE): Belgium, Brazil, Italy,             decelerated fiscal depreciation. Argentina, Australia, Brazil,
    Liechtenstein and Turkey. Including this provision in their tax           South Africa and Spain provide moderately decelerated
    code has led to an additional reduction in their EATRs of                 depreciation of intangibles. On the other hand, a significant
    1.3-4.4 percentage points.                                                number of jurisdictions accelerates depreciation of
                                                                              intangibles, including Denmark, Kenya, Papua New Guinea
l   The average EATR across jurisdictions (20.5%) is 1.1 percentage           and the United States.
    points lower than the average statutory tax rate (21.6%).
    EATRs are also less dispersed across jurisdictions compared           l   Comparison of statutory tax rates and the degree of
    to the statutory tax rate. While the median is about the same             acceleration measured in percentage points suggests
    as for the statutory tax rate, the highest EATR is only 44.1%,            that jurisdictions with higher statutory tax rates tend to
    compared to the highest statutory tax rate at 47.9%; half of the          provide stronger fiscal acceleration, especially among OECD
    jurisdictions covered have EATRs between 14.5% and 27.4%.                 jurisdictions.
18 . OECD | CORPORATE TAX STATISTICS

CORPORATE EFFECTIVE TAX RATES 2017

ETRs fall into two categories: forward-looking and         l EATRs reflect the average tax contribution a firm
backward-looking ETRs. Forward-looking ETRs capture          makes on an investment project earning above-zero
information on corporate tax rates and bases as well         economic profits. This indicator is used to analyse
as other relevant provisions within a comparable             discrete investment decisions between two or more
framework. They provide an appropriate basis for cross-      alternative projects (along the extensive margin).
jurisdiction comparisons of the combined impact of
corporate tax systems on the investment decisions          In contrast, backward-looking ETRs are calculated by
of firms. Although these forward-looking ETRs do not       dividing actual tax payments by profits earned over a
reflect actual tax payments by specific taxpayers in the   given period. They are calculated on the basis of historical
past, they are accurate indicators of the investment       jurisdiction-level or firm-level data and reflect the combined
incentives delivered by corporate tax systems and          effects of many different factors, such as the definition
therefore provide comparable information on the            of the tax base, the types of projects that firms have been
competitiveness of tax systems.                            engaged in, as well as the effects of possible tax-planning
                                                           strategies. Although backward-looking ETRs may not reflect
Two complementary forward-looking ETRs are typically       how corporate tax systems affect incentives to invest at
used for tax policy analysis, capturing incentives at      present, they provide information on how tax payments and
different margins of investment decision making:           profits of specific taxpayers or groups of taxpayers compare
                                                           to each other in the past. Therefore, backward-looking ETRs
l EMTRs measure the extent to which taxation               are often referred to in public debates about multinational
  increases the pre-tax rate of return required by         tax avoidance and BEPS. The second edition of Corporate Tax
  investors to break even. This indicator is used to       Statistics will include aggregated and anonymised data from
  analyse how taxes affect the incentive to expand         Country-by-Country Reports allowing for the calculation
  existing investments given a fixed location (along the   of some backward-looking ETRs for certain groups of
  intensive margin).                                       multinational enterprises.

                 Among the 55 jurisdictions that provide accelerated depreciation, the average
                 reduction of the statutory tax rate was 1.8 percentage points.
CORPORATE EFFECTIVE TAX RATES . 19

Box 5. KEY CONCEPTS AND METHODOLOGY

Forward-looking effective tax rates (ETRs) are calculated on        l   The effective average tax rate (EATR) reflects the average
the basis of a prospective, hypothetical investment project.            tax contribution a firm makes on an investment project
The OECD methodology has been described in detail in the                earning above-zero economic profits. It is defined as the
OECD Taxation Working Paper No. 38 (Hanappi, 2018), building            difference in the NPV of pre-tax and post-tax economic
on the theoretical model developed by Devereux and Griffith             profits relative to the NPV of pre-tax income net of real
(1999, 2003).                                                           economic depreciation.
                                                                                                    pre-tax                          post-tax
The methodology builds on the following key concepts:                            (Economic profit    NPV      ) – (Economic profit     NPV )
                                                                        EATR =
                                                                                                                   pre-tax
                                                                                                (Net income         NPV      )
l   Economic profits are defined as the difference between
    total revenue and total economic costs, including explicit      l   Real economic depreciation is a measure of the decrease
    costs involved in the production of goods and services as           in the productive value of an asset over time; depreciation
    well as opportunity costs such as, for example, revenue             patterns of a given asset type can be estimated using asset
    foregone by using company-owned buildings or self-                  prices in resale markets. The OECD methodology uses
    employment resources. It is calculated as the net present           economic depreciation estimates from the US Bureau of
    value (NPV) over all cash flows associated with the                 Economic Analysis (BEA, 2003).
    investment project.
                                                                    l   Jurisdiction-specific tax codes typically provide capital
l   The cost of capital is defined as the pre-tax rate of return        allowances to reflect the decrease in asset value over time
    on capital required to generate zero post-tax economic              in the calculation of taxable profits. If capital allowances
    profits. In contrast, the real interest rate is the return on       match the decay of the asset’s value resulting from it
    capital earned in the alternative case, for example, if the         being used in production, then fiscal depreciation equals
    investment would not be undertaken and the funds would              economic depreciation.
    remain in a bank account.
                                                                    l   If capital allowances are more generous, fiscal depreciation
l   The effective marginal tax rate (EMTR) measures the                 is accelerated; where capital allowances are less generous,
    extent to which taxation increases the cost of capital; it          fiscal depreciation is referred to as decelerated. The NPV
    corresponds to the case of a marginal project that delivers         of capital allowances, measured as percentage of the initial
    just enough profit to break even but no economic profit             investment, accounts for timing effects on the value of
    over and above this threshold.                                      capital allowances, thus providing comparable information
                                                                        on the generosity of fiscal depreciation across assets and
                   (Cost of capital) – (Real interest rate)             jurisdictions.
         EMTR =
                              (Cost of capital)
                                                                    The cost of capital, EMTR, EATR as well as the NPV of capital
                                                                    allowances are all available for 74 jurisdictions in the
                                                                    Corporate Tax Statistics online database.
20 . OECD | CORPORATE TAX STATISTICS

EFFECTIVE AVERAGE TAX RATES

Figure 9 shows the composite EATR for the full database,           To allow comparison with the statutory tax rate, the
ranking jurisdictions in descending order. In most                 share of the EATR (in percentage points) that is due to
jurisdictions, EATRs diverge considerably from their               a deceleration of the tax base is shaded in light blue
statutory tax rate; if fiscal depreciation is generous             in Figure 9; reductions of the statutory tax rate due to
compared to true economic depreciation or if there are             acceleration are transparent. In addition, the reduction
other significant base narrowing provisions, the EATR              in the EATR due to an ACE is indicated as a striped area.
(and also the EMTR) will be lower than the statutory tax           The composite EATR corresponds to the combination of
rate, i.e. tax depreciation is accelerated. On the contrary,       the unshaded and shaded blue components of each bar, as
if tax depreciation does not cover the full effects of true        indicated by the red line marker. Across the entire sample
economic depreciation, it is decelerated, implying that the        of jurisdictions, the EATRs range from around 44% in India
tax base will be larger and effective taxation higher.             to 0% in the British Virgin Islands, Turks and Caicos Islands,
                                                                   Saudi Arabia, Isle of Man, Jersey, Guernsey, and the Cayman
  Box 6. ASSET CATEGORIES AND TAX PROVISIONS                       Islands. Ranking just above these jurisdictions, Andorra,
  COVERED                                                          Bulgaria and Hungary have EATRs around 9%, the lowest
                                                                   non-zero rates in the sample.
  The calculations build on a comprehensive coverage
  of jurisdiction-specific tax rules pertaining to four            Comparing the patterns of tax depreciation across juris­
  quantitatively relevant asset categories:                        dictions shows that most jurisdictions provide some degree
                                                                   of acceleration, as indicated by the transparent bars;
  1. buildings: e.g. office buildings or manufacturing plants;
                                                                   the most significant effects are observed in jurisdictions
  2. machinery: e.g. machinery, cars, furniture or equipment;      with an ACE, such as Belgium, Brazil and Italy, as well
                                                                   as in jurisdictions with generous bonus depreciation
  3. inventories: e.g. goods or raw materials in stock;
                                                                   schemes, such as India and the United States. While fewer
  4. intangibles: e.g. acquired patents or trademarks.             jurisdictions have decelerating tax depreciation rules, the
                                                                   effect of deceleration can become quite large in terms
  The following corporate tax provisions have been covered:
                                                                   of percentage point increases compared to the statutory
  l   combined central and sub-central statutory corporate         tax rate; e.g. in Botswana, Chile and Costa Rica, where
      income tax rates;                                            intangible assets are non-depreciable.
  l   asset-specific fiscal depreciation rules, including first-
      year allowances, half-year or mid-month conventions;           Box 7. MACROECONOMIC SCENARIOS
  l   general tax incentives only if available for a broad           The two main macroeconomic parameters, inflation and
      group of investments undertaken by large domestic or           interest rates, interact with the effects of the tax system
      multinational firms;                                           in various ways and can have ambiguous effects on the
  l   inventory valuation methods including first-in-first-out,      effective tax rates (ETRs).
      last-in-first-out and average cost methods;                    The Corporate Tax Statistics database contains ETR results for
  l   allowances for corporate equity.                               three different macroeconomic scenarios. In the first two
                                                                     scenarios, interest and inflation rates are held constant; the
  The composite ETRs reported in this brochure are constructed
                                                                     third scenario uses jurisdiction-specific macroeconomic
  in three steps. First, ETRs are calculated separately for each
                                                                     parameters. While the former approach addresses the question
  jurisdiction, asset category and source of finance (debt and
                                                                     of how differences in tax systems compare across jurisdictions
  equity); while the debt-finance case accounts for interest
                                                                     holding other factors constant, the latter approach gives better
  deductibility, jurisdiction-specific limitations to interest
                                                                     indications on the tax effects on investment incentives in a
  deductibility have not been covered in this edition. Second,
                                                                     specific jurisdiction at a specific point in time.
  an unweighted average over the asset categories is taken,
  separately for both sources of finance. Third, the composite       The results published in this brochure build exclusively on
  ETRs are obtained as a weighted average between equity-            the macroeconomic scenario with constant 3% interest and
  and debt-financed investments, applying a weight of 65%            1% inflation rates, however, results from the two additional
  equity and 35% debt finance.                                       macroeconomic scenarios are available in the online database.
CORPORATE EFFECTIVE TAX RATES . 21

FIGURE 9: Effective average tax rate: OECD, G20 and participating Inclusive Framework jurisdictions, 2017

  IND
   CRI
ARG
 USA
 MLT
 FRA
 CHL                                                                                                                                     Lo
COD
 AUS
MSR
 BRA
 SYC
  PER
 GRC
 SEN
  PRT
  JPN
MEX
BWA
DEU
 ZAF
 KEN
 NZL
PNG
  BEL
  ESP
CAN
 LUX
 AUT
CHN
JAM
 KOR
NOR
 NLD
   ISR
  IDN
   ITA
 SVK
 THA
 CZE
CUW
 TUR
SWE
 CHE
DNK
 GBR
   FIN
    ISL
 RUS
 SVN
 POL
  EST
 SGP
 HRV
HKG
 ALB
ROU
MUS
  LVA
  LTU
 CYP
   IRL
MAC
   LIE                                                                          Acceleration: EATR decrease compared to STR (pp)
HUN
 BGR                                                                            Deceleration effects counterbalanced by ACE (pp)
AND
                                                                                Deceleration: EATR increase compared to STR (pp)
 VGB
 TCA                                                                            EATR reduction due to ACE (pp)
 SAU
   JEY                                                                          EATR
 IMN
GGY                                                                             Statutory Corporate Tax Rate
CYM
          0%   5%         10%        15%         20%         25%        30%            35%         40%            45%              50%
22 . OECD | CORPORATE TAX STATISTICS

EFFECTIVE MARGINAL TAX RATES

Figure 10 shows the ranking based on the composite           If investment projects are financed by debt, it is also
EMTR. As highlighted above, the EMTR measures the            possible for the EMTR to be negative, which means that
effects of taxation on the pre-tax rate of return            the tax system, notably through interest deductibility,
required by investors to break even. While the effects       reduces the pre-tax rate of return required to break even
of tax depreciation and macroeconomic parameters             and thus enables projects that would otherwise not
work in the same direction as in the case of the EATR,       have been economically viable. Figure 10 shows that the
their impacts on the EMTR will generally be stronger         composite EMTR, based on a weighted average between
because marginal projects do not earn economic profits       equity- and debt-financed projects, is negative in 7 out
(see Box 5). As a consequence, jurisdictions with high       of 74 jurisdictions; this result is due to the combination
statutory tax rates and generous capital allowances,         of debt finance with comparatively generous tax
notably India and the United States, rank much lower         depreciation rules. For jurisdictions with an ACE, the
than in Figure 9. On the other hand, jurisdictions with      composite EMTR will generally be lower because of the
decelerating fiscal depreciation, including Australia, the   notional interest deduction available for equity-financed
Czech Republic, Slovakia or Thailand, are ranked higher      projects.
up based on the EMTR, as shown in Figure 10.

                  5 jurisdictions had an allowance for corporate equity (ACE): Belgium, Brazil, Italy,
                  Liechtenstein and Turkey. Including this provision in their tax code has significant
                  effects on the incentive to expand existing investments as measured by the EMTR.
CORPORATE EFFECTIVE TAX RATES . 23

 FIGURE 10: Effective marginal tax rate: OECD, G20 and participating Inclusive Framework jurisdictions,2017
                                                                      CRI
                                                                    CHL
                                                                    AUS
                                                                   ARG
                                                                   MSR
                                                                   BWA
                                                                    CZE
                                                                     ESP
                                                                    SVK
                                                                    TUR
                                                                    THA
                                                                    GBR
                                                                    MLT
                                                                    GRC
                                                                   NOR
                                                                     PER
                                                                    KOR
                                                                    NZL
                                                                      ISR
                                                                    FRA
                                                                    SYC
                                                                    AUT
                                                                   CHN
                                                                   JAM
                                                                      FIN
                                                                    ALB
                                                                       ISL
                                                                     PRT
                                                                    SEN
                                                                   CUW
                                                                    SVN
                                                                   DEU
                                                                   CAN
                                                                    RUS
                                                                    SGP
                                                                    NLD
                                                                     JPN
                                                                    ZAF
                                                                    CHE
                                                                    POL
                                                                   SWE
                                                                    CYP
                                                                   MAC
                                                                   MEX
                                                                   MUS
                                                                      IRL
                                                                    LUX
                                                                   HKG
                                                                   COD
                                                                   ROU
                                                                     IDN
                                                                     LVA
                                                                    BGR
                                                                   HUN
                                                                   DNK
                                                                   AND
                                                                    KEN
                                                                     LTU
                                                                    HRV
                                                                    VGB
                                                                    TCA
                                                                    SAU
                                                                      JEY
                                                                    IMN
                                                                   GGY
                                                                     EST
                                                                   CYM
                                                                             PNG
                                                                             LIE
                                                                             USA
                                                                             BRA
                                                                             ITA
                                                                             IND
                                                                             BEL

-50%         -40%          -30%           -20%          -10%             0%         10%            20%         30%
24 . OECD | CORPORATE TAX STATISTICS

EFFECTIVE TAX RATES BY ASSET CATEGORIES

The composite ETRs can be further disaggregated by           mean EATR for investments in intangibles suggests that
asset categories; jurisdiction-level EATRs and EMTRs         there are several outliers at the top of the distribution.
by asset categories are available in the online Corporate
Tax Statistics database. Figure 11 summarises these data     The lower panel depicts further information illustrating
on asset-level ETRs. The upper panel provides more           the EMTR distribution for each of the asset categories.
information on the distribution of asset-specific EATRs,     From this graph, we can draw the following insights:
comparing them to the distribution of statutory tax
rates. The first vertical line depicts information on the    l Investments in machinery benefit more often from
statutory tax rates; it shows that the mean (i.e. the red      accelerated tax depreciation than other investments;
triangle in the middle of the first vertical line) and the     as a result, the corresponding vertical line is more
median (the blue circle) are both around 22%, while the        condensed and centred around zero.
50% of jurisdictions in the middle of the distribution
have statutory tax rates between 16% and 30%.                l Investments in buildings are also often accelerated,
                                                               as evidenced by the vertical line that ranges from 0%
The other four vertical lines in the upper panel of            to around 9%.
Figure 11 illustrate the distribution of EATRs across
jurisdictions for each of the four asset categories:         l Investments in inventories often benefit from lower
buildings, machinery, inventories and intangibles.             EMTRs, compared to the statutory tax rate, although
Comparing them with the statutory tax rate shows               to a lesser extent than the first two asset categories.
that the distribution of EATRs is more condensed for
investments in buildings and machinery. For both of          l Marginal investments in intangibles can be subject to
these asset categories, the middle 50% of jurisdictions        very different EMTRs in different jurisdictions, reflected
have EATRs between around 14% and 26%, however,                in the vertical line that stretches out more than the
the mean EATR on investments in machinery is around            others, ranging from around 0% to just below 30%.
2 percentage points lower than the median, indicating          This result is driven, on the one hand, by the variation
that some jurisdictions have much lower EATRs on this          surrounding the actual economic depreciation of
type of investment. For investments in the other two           intangible assets as well as, on the other hand, different
asset categories, the distributions are similar to the         policy treatments across jurisdictions.
statutory tax rate, although the comparatively high
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