Competing with whom? For what? And how?

Arjan Reurink & Javier Garcia-Bernardo
Tax Justice Network annual conference | London, 2-3 July, 2019

The great fragmentation of the firm, FDI attraction profiles, and the structure of international tax competition in the European Union

PART I:

THE GREAT FRAGMENTATION OF THE FIRM

Fragmentation at two levels of corporate organization

Operational level

• Unbundling

• Offshoring

• Outsourcing

• Insourcing

Legal-financial level

• Interposition of holding companies

• Rearrangements of assets and risks

• Innovative financing arrangements

The anatomy and geographical dispersion of corporate groups (I)

Operational entities

• Manufacturing affiliates

• Shared service centers

• R&D facilities

Legal-financial entities

• Top holding companies

  • Full fledged global HQ

  • Legal/Tax home

• Intermediate holding companies

  • Regional HQs

  • IP management

  • Leasing companies

  • Group Treasury

The anatomy and geographical dispersion of corporate groups (II)

PART II:

TAX COMPETITION IN THE ERA OF THE GREAT FRAGMENTATION

Cluster 2

Cluster 3

Cluster 1

Thanks!

@ArjanReurink

@JavierGB_com

FDI attraction profiles