The impact of the global minimum tax on incentives for business location, investment, and profit shifting

Abstract In 2021, over 140 countries agreed to what is widely considered to be the most significant reform of international business taxes in a century: the introduction of a global minimum tax (GMT) at a rate of 15% on the profits of large MNEs. We study the reform’s impact on three interrelated MNE decisions: the location of investment, the size of investment conditional on location, and the extent to which profit is shifted to a low-tax country. We extend existing models of the impact of taxation on investment incentives to allow for profit shifting and the GMT. We also develop and quantify a measure of the economic cost of tax-induced distortions to location. We apply our model to taxes in 34 OECD countries. Raising the GMT rate reduces profit shifting as the benefits of profit shifting are reduced. This raises the MNE’s tax liability and its cost of capital, reducing its aggregate investment. The impact on location choice is more subtle, as the dispersion in effective tax rates across countries first rises, then falls, as the GMT rate rises. At a GMT rate of 15%, we estimate that there is a small rise in the dispersion, implying greater distortions to location decisions.