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

Activity indicators

Benefits

Macro-institutional features

Cluster 2

Cluster 3

Cluster 1

Tax features

Thanks!

@ArjanReurink

@JavierGB_com

FDI attraction profiles

Great fragmentation

By Javier GB

Great fragmentation

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