Calculating the country risk embedded in treaty-shopping networks

Abstract

This paper constructed a tax treaty network to measure the country risk embedded in treaty-shopping networks. The results showed that when moving dividends directly without treaty shopping, MNEs were taxed at 11.2 %, but with treaty shopping, a tax rate of 5.3 % was imposed. When detouring around risk countries, MNEs paid taxes at a rate of 4.5 %. Clearly, MNEs can minimize their tax burdens by detouring around risk countries. In the case of dividends, intermediate routes included the UK, Sweden, Kuwait, Spain, and Denmark. These countries except the UK were not previously known as conduit countries. We also looked at network changes in individual countries. When moving funds outward from China, Iran, and Venezuela, MNEs detouring around risk countries incurred reduced tax-saving benefits on interest income and royalty income. However, when moving funds from the US to China, Saudi Arabia, Japan, Russia, Ireland, and the UK, treaty-shopping benefits remained unchanged even if risk countries were bypassed. Among risk countries, those with less risk applied higher tax rates. In the case of dividends, the riskier the country, the lower the dividend income tax rate. This situation results from a desire to attract FDI. We reflected the country risk in our treaty-shopping model.