A Tax Map of Global Professional Service Firms: Where Expert Services are Located and Why

The role of multi-disciplinary Global Professional Service Firms (GPSFs) in the architecture of international tax abuse has been very little studied. Although it has been known that some of these firms operate in many of the world’s secrecy jurisdictions the scale of their activity in these, and other, locations has been little understood. Nor has their own representations of their tax services been appropriately considered. This working paper seeks to redress this deficiency. We locate the activities of these firms in the broader context of their activities around the globe, since it is the boast of many of them that they operate in more than 140 jurisdictions, worldwide. The research has revealed the opacity of the data surrounding these firms, and the unusual nature of their ownership structures. Financial reports of these firms are not available for most jurisdictions in which they work, whilst common control through ownership structures rarely crosses national boundaries. Using global directories of the firms as indication of presence in a location and the number of employees by jurisdiction as an indication of scale, our research indicates the disproportionate activity of particular GPSFs firms, namely the ‘Big Four’ accountancy firms, providing tax based services in secrecy jurisdictions. This suggests that they are major suppliers of offshore financial services. We consider the evolution of these GPSFs since the 1990s, suggesting they have been conscious participants in this activity but that their behaviour has adapted over time to reflect prevailing taxation morés to preserve the reputations of those supplying these services. As we show, these morés are reflected in their own presentation of their services as promoted on their web sites, which have changed significantly over time to reflect this fact, with little evidence that there has been any real underlying change in behaviour. As a result we suggest that these firms display a form of adaptive behaviour worthy of further study

Auditing with accountability : shrinking the opportunity spaces for audit failure

In recent years a number of high-profile company failures have raised fundamental questions about the willingness and/or ability of auditors to exercise the professional scepticism necessary for the production of robust audits. This report, co-written by Adam Leaver at the University of Sheffield and Leonard Seabrooke, Saila Stausholm and Duncan Wigan at Copenhagen Business School, examines the causes of those failures and makes a series of recommendations on how to resolve them. The report argues that audit failure takes place within a particular configuration of economic, cultural and regulatory arrangements which create the 'opportunity spaces' for poor practice. Shrinking those opportunity spaces therefore requires a multi-dimensional response, including the structural separation of audit and non-audit functions, a more robust system of fines and the integration of a civil society voice into the reform process to prevent regulatory capture

Against hollow firms : repurposing the corporation for a more resilient economy

The Covid-19 pandemic is revealing latent weaknesses at large, well-established companies who may now require state support. This report argues that those weaknesses pre-date the current pandemic and are a consequence of excesses in the non-financial corporate sector during the post-2008 economy. Those excesses include: i) historically high levels of dividends and buybacks which, in many cases, exceeded earnings and hollowed out reserves ii) the growth of low-prime debt, which risks being downgraded to junk in the current crisis and iii) a build-up of ‘fair valued’ assets, often intangible assets such as goodwill, which are vulnerable to write downs that could push firms into negative shareholder equity

Global Governance Behind Closed Doors : The IMF Boardroom, the Enhanced Structural Adjustment Facility, and the Intersection of Material Power and Norm Change in Global Politics

Up on the 12th floor of its 19th Street Headquarters, the IMF Board sits in active session for an average of 7 hours per week. Although key matters of policy are decided on in the venue, the rules governing Boardroom interactions remain opaque, resting on an uneasy combination of consensual decision-making and weighted voting. Through a detailed analysis of IMF Board discussions surrounding the Enhanced Structural Adjustment Facility (ESAF), this article sheds light on the mechanics of power in this often overlooked venue of global economic governance. By exploring the key issues of default liability and loan conditionality, I demonstrate that whilst the Boardroom is a more active site of contestation than has hitherto been recognized, material power is a prime determinant of both Executive Directors’ preferences and outcomes reached from discussions. And as the decisions reached form the backbone of the ‘instruction sheet’ used by Fund staff to guide their everyday operational decisions, these outcomes—and the processes through which they were reached—were factors of primary importance in stabilizing the operational norms at the heart of a controversial phase in the contemporary history of IMF concessional lending

Taxing the powerful, the rise of populism and the crisis in Europe: the case for the EU Common Consolidated Corporate Tax Base

Contemporary populism is rooted in a crisis of legitimacy. Corporate taxavoidance by multinationals is one cause of that crisi s. Although states tend to beincreasingly formally committed to tackling avoidance, they do so in a system thatpromotes contradictory sets of behaviour. This tends to undermine attempts to solvethe problem of avoidance unless a more transformative collective approach is taken.Ironically, despite its own democratic deficit, the European Comm ission has taken aleading role in promoting such a solution: the Common Consolidated Corporate TaxBase (CCCTB). In this paper, I set out the case for ‘unitary taxation’ based on theCCCTB and state some of its current problems. The problem of corporation taxraises a basic issue in terms of who is sovereignty for, and solving the problemprovides an important contribution to legitimacy of both the state and the EU

Panama and the WTO : new constitutionalism of trade policy and global tax governance

"Corrigendum" in Review of International Political Economy, 24(4), p. 738 (DOI: 10.1080/09692290.2017.1332547).Tax havens and tax flight have lately received increasing attention, while interest toward multilateral trade policies has somewhat diminished. We argue that more attention needs to be paid exactly to the interrelations between trade and tax policies. Drawing from two case studies on Panama's trade disputes, we show how World Trade Organization (WTO) rules can be used both to resist attempts to sanction secrecy structures and to promote measures against tax flight. The theory of new constitutionalism can help to explain how trade treaties can 'lock in' tax policies. However, our case studies show that trade policy not only 'locks in' democratic policy-making, but also enables tax havens to use their commercialized sovereignty to resists anti-secrecy measures. What is being 'locked in' are the policy tools, not necessarily the policies. The changing relationship between trade and tax policies can also create new and unexpected tools for tackling tax evasion, underlining the importance of epistemic arbitrage in the context of new constitutionalism. In principle, political actors with sufficient technical and juridical knowledge can shape global tax governance to various directions regardless of their formal position in the world political hierarchies. This should be taken into account when trade treaties are being negotiated or revised.Peer reviewe

Corporation tax as a problem of MNC organisational circuits: The case for unitary taxation

The tax practices of multinational corporations have become a matter of significant public and political concern. The underlying issues are rooted in the capacity of multinational corporations (MNCs) to construct organisational circuits that shift where sales, revenue and profit are reported. This capacity in turn becomes a focus because of the way MNCs are treated as a series of separate entities, subject to the arm’s length principle. This has become a classic example of a system whose current form and consequences were not foreseen when the original principles were set out. The continued existence of that system owes more to specific interests and inertia than it does to the absence of a viable alternative. Unitary taxation based on formula apportionment clearly resolves the underlying issues and unitary taxation may well ultimately emerge as a new generalised basis for corporate taxation. However, for it to do so, the problems of the current system and the advantages of the alternative need to be more clearly understood within academia, business and on a societal basis. This paper is a contribution to such an understanding

Grey matter in shadow banking: international organizations and expert strategies in global financial governance

Who controls global policy debates on shadow banking regulation? We show how experts secured control over how issues in shadow banking regulation are treated by examining the policy recommendations of the Bank of International Settlements, the International Monetary Fund and the Financial Stability Board. The evidence suggests that IO experts embedded a bland reformism opposed to both strong and ‘light touch’ regulation at the core of the emerging regulatory regime. Technocrats reinforced each other's expertise, excluded some potential competitors (legal scholars), co-opted others (select Fed and elite academic economists), and deployed measurement, mandate, and status strategies to assert issue control. In the field of shadow banking regulation, academic economists’ influence came from their credibility as arbitrageurs between several professional fields rather than their intellectual output. The findings have important implications for how we study the relationship between IO technocrats and experts from other professional field

The Political Economy of Failure: The Euro as an International Currency

How do international currencies get established and consolidated? What domestic and international political foundations support an international currency? And what kinds of macro-economic flows enable an international currency? In this essay we consider these perennial questions of modern IPE scholarship in reverse order to ask whether the euro could ever have become, or seek to become, a true international currency rivalling the US dollar, used not only for passive foreign exchange reserves but also as a major commercial currency outside the EU. We argue that the EU lacks the will, the ideas and the capacity to promote the euro into the status of an international currency. In this article, we concentrate on this final issue of capacity, as the will and ideas issues have already been well explored. Capacity is an issue coeval with, if not prior to, the first two issues. The EU's current institutional arrangements and its economic geography create macro-economic consequences that diminish the euro's capacity to operate as a top currency. These conflicts go beyond the well-recognized issue that the euro-zone is not an optimum currency area. Examining the euro's debilities sheds light not only on the euro's (in)capacity to rival the dollar as an international currency, but also on the future of both the euro and the dollar in the aftermath of the euro-zone crisis