1000' employees Figure E.2: Governments vs.

corporate transfer pricing

250 specialists
231.9

200

150
Wage bill ≈ €15 Billion

100

50

0
2.4
Government Private
Source is LinkedIn, but the government count is corroborated by the EY Transfer Pricing Tax Authority Survey (2014). The wage bill is estimated by applying the
average salary of an EY Transfer Pricing Specialist (Source: Glassdoor).
 Figure F.1: Profits of foreign owned firms (% of global
18% profits)
16%

14%

12%

10%

8%

6%

4%

2%

0%
1930-39 1940-49 1950-59 1960-69 1970-79 1980-89 1990-99 2000-09 2010-15
 Figure G.1: High risk service exports and FDI-interest
400% (% of GNI)
350% Pharmaceutical exports

300% FDI interest received

250% High risk service exports

200%
EU22 average
150%
100%
50%
Average among EU22: 5%
0%

Note: This figure illustrates the income generated from high-risk service exports and FDI-interest as share of Gross National Income in the EU in 2015. High-risk services are
defined as services within the five categories: "Intellectual property", "Telecommunications, computer and information services", "Financial services", "Other business services"
and "Insurance and pension services". The bars show the split between income from exports of high-risk services and interest income. The green line shows the GNI-weighted
average sum of the two incomes combined for all non-haven countries in the EU. The difference between EU28 and EU22 is the exclusion of the havens: Belgium, Cyprus,
Ireland, Luxembourg, Malta and Netherlands.
 Figure G.2: High risk service exports and FDI-interest
(% of GNI)
400%
350% Non-EU

300%
EU
250%
EU22 average
200%
150%
100%
50% Average among EU22: 5%
0%

Note: This figure illustrates the income generated from high-risk service exports and FDI-interest as share of Gross National Income in the EU in 2015. High-risk services are
defined as services within the five categories: "Intellectual property", "Telecommunications, computer and information services", "Financial services", "Other business services"
and "Insurance and pension services". The bars show the split between income from EU and non-EU countries. The green line shows the GNI-weighted average sum of the two
incomes combined for all non-haven countries in the EU. The difference between EU28 and EU22 is the exclusion of the havens: Belgium, Cyprus, Ireland, Luxembourg, Malta
and Netherlands.
€ Bn. Figure H.1: The missing service exports of Luxembourg
60

50

40

30

20

10

0
Reported by EU Reported by Luxembourg

Note: EU is the European Union minus the 6 EU tax havens (Netherlands, Ireland, Luxembourg, Cyprus, Malta, and Belgium).
€ Bn. Figure H.2: The missing service exports of the six EU tax
70 havens
Reported by exporter
60
Reported by importer
50

40

30

20

10

0
Luxembourg Ireland Belgium Netherlands
 Figure H.3: Missing service exports, % of total service
60% exports

50%

40%

30%

20%

10%

0%
EU22 EU6 Luxembourg Ireland Belgium Netherlands Malta

Note: Service exports include exports to all EU22 countries (EU26 minus Luxembourg, Ireland, Belgium, Netherlands, Malta, Cyprus).
 Figure I.1: Tax competition and the rise of
Corp. tax rate MNE profit share
50%
multinationals 18%
World average corp. tax rate
45% 16%
40% 14%
35%
12%
30%
10%
25%
08%
20%
06%
15%
10% 04%
Multinational profits (% of all profits)
5% 02%

0% 00%
1981-1989 1990-1999 2000-2009 2010-2018
Notes: This figure charts the unweighted world average corporate tax rate and the share of global corporate profits made by multinational corporations. Multinational
profits were around €1.4 trillion in 2015, while global corporate profits were around €7.9 trillion.
 Figure I.2: Global corporate tax rates (%)
34%

32%
Africa

30%

28%
World
26% Latin America

24%
EU
22% Asia

20%

18%
2003 2004 2005 2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016 2017 2018
 Figure I.3: Global corporate tax rates (%)

38% United states

34%

Africa
30%

World Latin America

26%
EU

22% Asia

18%
2003

2004

2005

2006

2007

2008

2009

2010

2011

2012

2013

2014

2015

2016

2017

2018
 Figure J.1: Distribution of Danish transfer price corrections
Pct. of total
(cases)
70%
Non-EU EU
60%

50%

40%

30%

20%

10%

0%
Non tax havens Tax havens Counterpart unknown
Note: The graph plots the distribution of the number of transfer price corrections by counterpart. Transfer price corrections are cases in which the Danish tax authority have
corrected an intra-group cross-border transfer price and as a result raised the taxable profits of firms operating in Denmark. The counterpart is the country that the Danish tax
authority argue have received excessive taxable profits. The graph shows that the counterpart in 40% of the cases is a high tax EU country (Non tax haven) and in 24% of the cases
is a non-EU high tax country.
 Figure K.1: FDI income paid by Ireland
50 (€, Bn.)
45
40
35 As reported by Ireland As reported by partner country
30
25
20
15
10
5
0
 -10
0
10
20
30
40
50
United States
Netherlands
Bermuda (UK)
Switzerland
Cayman Islands
United Kingdom
Luxembourg
France
Italy
Belgium
Germany
Spain
Sweden
Denmark
Portugal
Ireland

Singapore
Malta
Canada
Japan
Hungary
British Virgin Islands (UK)
Bulgaria
Czech Republic
Estonia
FDI income according to partners

Greece
Croatia
Figure K.1b: FDI income owed by Ireland (€, Bn.)

Latvia
Lithuania
Inward FDI income in Ireland according to

Poland
Romania
Slovenia
 Figure K.2: FDI income owed by Ireland (€, Bn.)
50
45 Inward FDI income in Ireland according to
Ireland
40
FDI income according to partners
35
30
25
20
15
10
5
0
United States European Union Offshore financial Rest of World
(current composition) centers
 Figure L.1: Pre-tax profits of affiliates of US multinationals,
800% 2015 (% of compensation of employees)

700% Tax havens

600% Non havens

500%

400%

300%

200%

100%

0%
Chemical Wholesale Finance Professional Other
Computers trade Information services
 Figure M.1: Countries most often targeted in transfer price
# of times country is
among top 3 targets disputes (by countries with a functioning MAP-system)
12

10