Taxing Income in the Oil and Gas Sector - Challenges of International and Domestic Profit Shifting

This paper provides specific estimates on the scale of profit shifting amonghydrocarbon MNEs. We estimate a lower-bound semi-elasticity of reported profits to sector specific income taxation of -1.88. To assess the importance of domestic profit-shifting channels, we take advantage of domestic tax differentials among hydrocarbon producers facing additional rent taxes and find that domestic profit shifting accounts for about one third of total income concealed. Overall, we estimate revenue losses in the sector due to profit-shifting amount to 12% - 35% of the income tax base, depending on the characteristics of a country's tax regime. We also observe a higher vulnerability of non-OECD economies to profit shifting in our sample, which consists of 294 domestic and multinational parents and subsidiaries during the period from 2004-2012. Finally, our analysis confirms the mitigation effect of documentation requirements for internal transactions. However, we also find that increased enforcement prompts MNEs in the Oil and Gas sector to rely more heavily on the reallocation of profits at the domestic level.