## d4-corporate-inversions

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### SECTION I: THE ISSUE — background, definitions, and typology
- Definition and mechanics:
  - A corporate inversion: corporate restructuring of a transnational enterprise group such that the original parent company in one economy becomes a subsidiary of a new parent in another economy; ownership of a group of enterprises may be shifted to the new parent company (BPM6, paragraph 8.19).
  - Typical transactions involve exchange of shares and designation of the lower-tax economy as the legal residence of the combined entity, often with no change in geographical allocation of headquarter functions.
  - Resulting positions: a direct investment (DI) relationship is created from the economy of the new foreign parent company to the economy of the inverter; a portfolio relationship is created by the economy of the inverter to the economy of the new foreign parent company.
  - BPM6 notes inversions can involve large financial-account values with little or no movement in resources and suggests supplementary data could be provided (BPM6, paragraph 8.20).

- Incidence and measured scale (selected estimates):
  - The United States accounted for 21 percent of the dollar value of a large sample of inversions in OECD countries (Col et al., 2019).
  - Undistributed profits of resident corporate inversions in Ireland in 2014: 6.9 billion euro, representing 11.0 percent of Ireland’s primary income receipts in 2014 (Fitzgerald, 2015).
  - Resident corporate inversions contributed 9.1 billion euro to the Netherlands’ primary income balance in 2017, representing 3.4 percent of primary income receipts in 2017 (Nelisse and Hiemstra, 2019).
  - In 2012 corporate inversions accounted for 5.4 percent of the DI equity position in the United States (Hanson et al., 2015).
  - ONS (2016) finds little evidence that re-domiciling headquarters has adversely affected UK FDI statistics in recent years.
  - Corporate inversion has been relevant for Italy where various Italian MNEs relocated legal residence abroad, usually to the Netherlands.

- Macroeconomic and statistical effects:
  - Inversions can have large effects on international and national accounts depending on the ratio between the size of the inverting company and the size of the economy.
  - Different treatment of reinvested earnings under DI versus portfolio investment tends to reduce net primary income receipts and higher-level aggregates such as corporate profits and total gross national income.
  - Annex II (of the guidance note) provides details on effects on selected aggregates of the U.S. national income and product accounts.
  - DI established by inversion may not convey the same benefits to the recipient economy as traditional DI, especially when headquarters functions remain in the original economy.

- Typologies of inversion-related corporate actions:
  - Cortes et al. (2015) three classes for U.S. companies:
    - Pure inversion: foreign entity created as legal head office while headquarters functions remain in the United States.
    - Restructuring inversion: inverting company becomes foreign-owned by merger, leveraged buy-out, bankruptcy, or spin-off.
    - Born inverted: a new domestic company is established with a foreign entity as owner while headquarters functions remain in the United States.
  - Broader four-case typology:
    - (a) Cross-border restructuring between original parent and foreign subsidiary with new foreign parent incorporating in the foreign country (financial-account transactions).
    - (b) Cross-border share swap between shareholders of original parent and independent foreign company (financial-account transactions).
    - (c) Establishment of a new domestic company with a foreign entity as owner (born inverted), usually resulting in cross-border financial transactions.
    - (d) Change of residence without merger or transaction with another company; recorded as “other change in volume” (BPM6, paragraph 4.167) and BPM6, paragraph 8.19 indicates this restructuring should not be defined as a corporate inversion.

- Identification, data sources, and practical challenges:
  - Corporate inversions mainly involve listed groups; public information (press releases, reports) is widely available.
  - Complex restructurings may combine transactions and “other changes in volume,” requiring case-specific determinations and expert judgement.
  - Confidentiality constraints may limit publication of detailed identified-inversion statistics.

- Criteria for identifying the “true” corporate home (Anknüpfungspunkte / Sitztheorie elements):
  - a) Location where central management decisions are routinely made.
  - b) Location where the corporation was founded.
  - c) Nationality of majority shareholders or of executive officers.
  - d) Principal place of business or the state most strongly affected by the corporation’s activities (e.g., geographic center of the global labor force).
  - Desai (2008): home economy should be based on “critical managerial decision-making and the associated headquarters functions.”
  - Eurostat: term “Global Decision Centre” designates the “true” center of control.
  - Statistics Netherlands definition for inversions with new home in the Netherlands: entities born and undertaking initial growth stages abroad and having a relatively limited share of global activities in the Netherlands (Nelisse and Hiemstra, 2019).

- Issues for subsequent acquisitions and measurement by ultimate investor:
  - Conceptual question: whether subsequent acquisitions by the new foreign parent in the inverter’s economy should be treated as inversion-related.
  - A “winner takes all” ultimate control approach could align inversion statistics with DI statistics by ultimate investing economy.
  - Suggested operational approach: once a false foreign parent is identified, consider its subsequent acquisitions in the inverter’s economy as inversion-related, subject to confidentiality and practical constraints.

### SECTION I — Alternatives for statistical treatment (Issues for discussion)
- Alternative 1 (A1) — Maintain status quo (BPM6 paragraphs 8.19–8.22):
  - Rationale: Definition and identification not sufficiently precise; tracking some inversions difficult; confidentiality constraints; limited number of affected countries.
  - Recommendation under A1: No change beyond short guidance in BPM6; countries hosting inversion-related FDI might quantify activity in AMNE statistics.

- Alternative 2 (A2) — Strengthen guidance and define corporate inversions; publish supplementary detail:
  - Rationale: Inversion-related DI differs in motivation and impact from traditional DI; benefits from separate supplemental statistics.
  - Proposal elements:
    - Strengthen BPM6 paragraph 8.20 with richer description and encourage publication of supplementary detail (DI flows, positions, and income) if feasible and values are large.
    - Identification using objective criteria (Anknüpfungspunkte) or approaches informed by academic studies (Annex III).
    - Confidentiality mitigations: publish less-detailed statistics (e.g., positions only) or publish with lower frequency.
    - Consider subsequent acquisitions by identified false foreign parent as inversion-related.

- Alternative 3 (A3) — Record inversions as portfolio investment rather than DI:
  - Rationale: New foreign parent often does not supply additional contributions such as know-how, technology, management, and marketing (BPM6, paragraph 6.4); inversions may be financial engineering.
  - Implication: Treating inversions as portfolio would produce largely offsetting portfolio investment flows, replacing DI entries under current guidance.
  - Practical concerns: Question whether new foreign parents are separate institutional units (similar to SPEs, near-SPEs); raises question whether an international transaction occurred.

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### SECTION II: OUTCOMES — consensus, guidance, and recommendations
- Official definition and consensus:
  - DITT supports Alternative A2; corporate inversions reduce analytical usefulness of DI statistics because they are motivated by factors other than those conventionally ascribed to direct investors (BPM6, paragraph 6.4) (Paragraph 18).
  - Proposed official definition adopted for statistical purposes (Paragraph 19): “A corporate inversion describes the corporate restructuring of a transnational enterprise group such that the original parent company in one economy that is the ultimate parent of the corporate group becomes a subsidiary of the new parent in another economy. In addition, ownership of a group of enterprises may be shifted to the new parent company.”
  - Definition distinguishes inversions from other mergers and acquisitions by clarifying that only after inversions does the original parent become a subsidiary of a new parent in another economy.

- Practical compiler guidance and publication approaches (Paragraph 20):
  - Additional guidance will require effort and expert judgement to identify inversions.
  - Confidentiality and large, infrequent nature of inversion transactions can be managed by:
    - publishing data at higher levels of geographic aggregation and/or less frequent intervals;
    - providing annual data on direct and portfolio investment positions of inverted companies and on their primary income balance;
    - publishing information on retained earnings of the new parent companies.
  - Presentations remain supplemental and at the discretion of the reporting economy (BPM6 approach), depending on significance and availability of information.

- Scope of supplemental presentations (Paragraph 21):
  - Supplemental presentations may cover changes in residence under BPM6, paragraph 4.167, and other restructurings with similar economic effects.
  - Compilers may judge whether to include both financial-transaction-recorded inversions and “other changes in volume” changes in residence in supplemental presentations based on jurisdictional relevance.

- Consultation, typology feedback, and judgement (Paragraph 22):
  - GZTT consultation (November 2021): slight majority agreed with proposed definition; some concern that including “that is the ultimate parent of the corporate group” could cause confusion but limits definition to ultimate-parent cases.
  - Typology considered useful; suggestions for clarifications were incorporated in final Guidance Note.
  - Professional judgment may be required to assess whether reallocation of operational headquarters or administrative changes (e.g., ISIN-only changes) fall under the inversion definition (footnote observation).

- Committee decision and further action (Paragraph 24):
  - IMF Committee on Balance of Payments Statistics supported an official definition for BPM7.
  - Committee found a full typology of the most usual corporate actions useful, indicating whether actions should be recorded as transactions or as other changes in volume (OCV).
  - Committee agreed with voluntary supplemental data collection on inversions for countries where important and proposed further guidance in the BPM7 Compilation Guide.
  - DITT to consult with GZTT in finalizing Guidance Note; current GN version incorporates those discussions.

- Recommendations (Paragraph 23) — actionable items to include in BPM7:
  - Include a taxonomy of the most usual cases of corporate actions involving inversions or similar restructurings (as outlined in the typology).
  - Include the official definition of corporate inversion as in Paragraph 19.
  - Strengthen guidance on publishing supplementary detail on inversions; examples of supplemental presentations include annual data on:
    - direct and portfolio investment positions of inverted companies,
    - primary income balance of inverted companies,
    - retained earnings of the new parent companies.
  - Maintain these presentations as supplemental and at the discretion of the reporting economy.

- Rejected alternatives (Paragraphs 25–26):
  - Alternative A1 rejected: additional guidance is needed on identifying inversions and on the types of statistics useful to policymakers and analysts.
  - Alternative A3 rejected: recording inversions as portfolio investment does not resolve the conceptual question of whether an international transaction occurred and implementation would be difficult because both sides of the transaction typically would not be covered by portfolio investment statistics.

- BPM6 guidance elements retained in recommendation (summary of key paragraphs 8.19–8.22):
  - 8.19: Inversion defined as corporate restructuring where original parent becomes a subsidiary of a new parent in another economy; achieved by transactions in assets and recorded as financial transactions.
  - 8.20: Operational structure and ultimate shareholders remain effectively unchanged; new parent benefits from taxation and regulatory environment of incorporation; inversions can involve large financial-account values with little or no movement in resources; supplementary data could be provided if confidentiality allows.
  - 8.21: Accounting treatment: assets of the original parent treated as returned to shareholders through withdrawal of equity and reinvested in the new parent at the same value — a rearrangement of balance sheets via equality-valued equity transactions in the financial account.
  - 8.22: Assets may be shifted between enterprises because of restructuring; owners sell securities in the first enterprise and buy securities in the second (financial account entries, not capital transfers or other changes).

*Source: IMF Committee on Balance of Payments Statistics, Direct Investment Task Team Guidance Note — SECTION I: THE ISSUE and SECTION II: OUTCOMES.*

### SECTION I: THE ISSUE

### SECTION I: THE ISSUE

### Background and definition of corporate inversions
- Some multinational enterprises (MNEs) geographically locate (or re-locate) their economy of legal residence to reduce their global tax liability through a “corporate inversion”. The inversion strategy often involves an agreement between corporations in two countries: a corporation (“the inverter”) in one economy often merges with a corporation (“the new foreign parent company”) that is headquartered in a lower-tax economy.
- The underlying financial transactions typically involve an exchange of shares and an agreement to designate the lower-tax economy as the legal residence of the combined entity. There is usually no change in the geographical allocation of headquarter functions; at most, some or just a few board meetings are held in the economy of the new foreign parent company.
- Generally, a direct investment (DI) relationship is created from the economy of the new foreign parent company to the economy of the inverter and a portfolio relationship is created by the economy of the inverter to the economy of the new foreign parent company, as shareholders in the inverter are converted to shares in the new foreign parent company.
- Corporate inversions are not covered in the OECD Benchmark Definition of Foreign Direct Investment, fourth edition, 2008 (BD4).
- BPM6, paragraph 8.20, notes that “because inversions can involve large values in the financial account but with little or no movement in resources, there may be analytical interest in separating them from other direct investment. If not prevented by confidentiality, supplementary data could be provided.”

### Incidence and measured scale
- The incidence of corporate inversions is not widespread geographically and is not overwhelmingly a U.S. phenomenon. Col et al. (2019) found that the United States accounted for only 21 percent of the dollar value of a large sample of inversions in OECD countries.
- Fitzgerald (2015) estimates that the undistributed profits of resident corporate inversions in 2014 was 6.9 billion euro, which represents 11.0 percent of Ireland’s primary income receipts in that year.
- Nelisse and Hiemstra (2019) estimate that resident corporate inversions contributed 9.1 billion euro to the Netherlands’ primary income balance in 2017, which represents 3.4 percent of the economy’s primary income receipts in that year.
- Hanson et al. (2015) estimate that in 2012 corporate inversions accounted for 5.4 percent of the DI equity position in the United States.
- For the United Kingdom, the Office for National Statistics (ONS) (2016) finds “little evidence to suggest that companies re-domiciling their headquarters overseas have been having an adverse effect on UK foreign direct investment (FDI) statistics in recent years.”
- For Italy, corporate inversion is a relevant phenomenon; in recent years, various Italian MNEs have relocated abroad their economy of legal residence, usually to the Netherlands.

### Macroeconomic and statistical effects
- Corporate inversions can have large effects on the international and national accounts; the magnitude depends on the ratio between the size of the inverting company and the size of the economy.
- Under current guidelines, the different treatment of reinvested earnings on DI and portfolio investment will tend to reduce net primary income receipts and the higher-level national accounting aggregates that include them in their derivation—corporate profits and total gross national income.
- Annex II (of the guidance note) provides relevant details on the effect of inversions on selected aggregates of the U.S. national income and product accounts.
- It is doubtful that DI under a corporate inversion conveys the same benefits to the recipient economy as traditional DI, especially when key headquarters functions remain in the economy of the inverting company.

### Typology and common cases of inversion-related corporate actions
- Cortes et al. (2015) identify three classes of inversions for U.S. companies:
  - Pure inversion: The inverting company creates a foreign entity to serve as the legal head office while keeping the headquarters functions in the United States.
  - Restructuring inversion: The inverting company becomes foreign-owned through a merger, leveraged buy-out, bankruptcy, or spin-off.
  - Born inverted: When a new domestic company is established along with a foreign entity as owner but headquarters functions remaining in the United States.
- A broader typology of usual cases includes four cases:
  - (a) Cross-border restructuring between the original parent company (the inverter) and a subsidiary in a foreign country, with the new foreign parent company incorporating in the foreign country; often results in financial transactions recorded in the financial account.
  - (b) Cross-border share swap between shareholders of the original parent company and those of an independent company in a foreign country; similarly results in financial transactions recorded in the financial account.
  - (c) Establishment of a new domestic company with a foreign entity as the owner (born inverted); the establishment would usually result in cross-border financial transactions.
  - (d) Change of residence that does not involve any merger or transaction with another company; BPM6, paragraph 4.167 treats this as “change in residence of entities other than persons,” and it would be recorded as “other change in volume” because no financial transactions occurred. BPM6, paragraph 8.19 indicates this restructuring should not be defined as a corporate inversion.

### Identification, data sources, and practical challenges
- Since corporate inversions mainly involve listed groups, public information on these transactions is widely available (e.g., company press releases and reports).
- Recording corporate inversion transactions in external sector statistics can be a challenge for compilers, especially for complex corporate restructurings, and may benefit from more detailed guidance.
- It can be difficult to identify corporate inversions and to define them such that all types of inversions are covered. Complex restructurings may involve combinations of transactions and “other changes in volume,” requiring case-specific determination.
- Public statistical confidentiality constraints may limit the ability to publish detailed statistics on identified inversions.

### Criteria and approaches to identifying the “true” corporate home
- Identifying corporate inversions may require objective criteria similar to Sitztheorie elements (Ebke, 2002) to determine the “true seat” of a corporation. Possible criteria (Anknüpfungspunkte) include:
  - a) The location where central management decisions are routinely made;
  - b) The location where the corporation was founded;
  - c) The nationality of the majority of the corporation’s shareholders or of the firm’s executive officers;
  - d) The corporation’s principal place of business or the state that is most strongly affected by the activities of the corporation (e.g., the geographic center of the corporation’s global labor force).
- Desai (2008) argues that the home economy of a MNE should be based on “critical managerial decision-making and the associated headquarters functions.”
- Eurostat’s Structural Business Statistics uses the term “Global Decision Centre” to designate where the “true” center of control for these corporations is resident.
- Statistics Netherlands defined corporate inversions with new home countries in the Netherlands as those that (i) were born and undertook their initial growth stages abroad and (ii) had a relatively limited share of their global activities in the Netherlands (Nelisse and Hiemstra, 2019).

### Issues for subsequent acquisitions and measurement by ultimate investor
- A conceptual question arises on how to treat subsequent acquisitions by the new foreign parent of companies in the country of the inverter: whether these domestic companies should be considered inverting and whether such transactions are inversion-related.
- A tighter relation between corporate inversion statistics and DI statistics by ultimate investing economy could arise if both sets of statistics followed a similar control approach (“winner takes all”) based on the concept of the ultimate controlling institutional unit.
- One suggested approach: once a false foreign parent is identified, consider that all of its subsequent acquisitions in the economy of the inverted corporation are inversion-related—but confidentiality and practical constraints may require less detailed presentation (e.g., positions only, lower frequency).

### Alternatives for statistical treatment (Issues for discussion)
- Three alternatives were identified for the treatment of corporate inversions:

  - Alternative 1 (A1) — Maintain the methodological and presentational status quo (based on BPM6 paragraphs 8.19–8.22):
    - Rationale: Definition and identification of inversions are not sufficiently precise; tracking some inversions is difficult; confidentiality constraints may prevent publishing inversion statistics; the number of affected countries appears small.
    - Under A1, no change is recommended beyond short guidance in BPM6 paragraphs 8.19–8.22. Countries hosting inversion-related FDI might consider quantifying this activity in Activities of Multinational Enterprises (AMNE) statistics.

  - Alternative 2 (A2) — Strengthen guidance on publishing supplementary detail and define corporate inversions:
    - Rationale: Differences in motivation and impacts between inversion-related DI and traditional DI suggest benefits from publishing separate statistics as a supplemental item.
    - Proposal: Strengthen BPM6 paragraph 8.20 by offering a richer description of corporate inversions and encourage publication of supplementary detail (DI flows, positions, and income) if feasible and values are large.
    - Identification: Use objective criteria (Anknüpfungspunkte) or approaches informed by academic studies (Annex III) to identify inversions.
    - Confidentiality mitigations: Publish less-detailed statistics (e.g., positions only) or publish with lower frequency.
    - Suggestion: Once a false foreign parent is identified, consider subsequent acquisitions by that parent in the inverter’s economy as inversion-related.

  - Alternative 3 (A3) — Record corporate inversions as portfolio investment rather than DI:
    - Rationale: The new foreign parent often does not “supply additional contributions such as know-how, technology, management, and marketing” (BPM6, paragraph 6.4); inversions may be primarily financial engineering.
    - Implication: Treating inversions as portfolio would lead to largely offsetting portfolio investment flows, replacing what would otherwise be recorded as DI under current guidelines.
    - Practical note: Some new foreign parents might be questioned as to whether they are separate institutional units (similar to SPEs, near-SPEs), raising questions about whether an international transaction occurred.

*Source: IMF guidance note — SECTION I: THE ISSUE*

### SECTION II: OUTCOMES

### SECTION II: OUTCOMES

### Consensus and official definition
- Paragraph 18: The Direct Investment Task Team (DITT) supports Alternative A2, noting that corporate inversions reduce the analytical usefulness of direct investment (DI) statistics because they are motivated by factors other than those conventionally ascribed to direct investors (BPM6, paragraph 6.4).
- Paragraph 19: The note proposes adopting the definition referenced in BPM6, paragraph 8.19, with a minor integration: “A corporate inversion describes the corporate restructuring of a transnational enterprise group such that the original parent company in one economy that is the ultimate parent of the corporate group becomes a subsidiary of the new parent in another economy. In addition, ownership of a group of enterprises may be shifted to the new parent company.”
  - The definition distinguishes inversions from other mergers and acquisitions by clarifying that only after inversions does the original parent become a subsidiary of a new parent in another economy.
  - Guidance in BPM6, paragraphs 8.19–8.22, and academic literature (e.g., Cortes, Gomes, and Gopalan (2015)) provide additional context.

### Practical challenges and compiler guidance
- Paragraph 20: Developing additional guidance will require effort and may still demand a high degree of expert judgement from compilers to identify inversions.
- Paragraph 20: Data confidentiality and the large, infrequent nature of inversion transactions pose publication challenges; these can be managed by:
  - publishing data at higher levels of geographic aggregation and/or less frequent intervals;
  - providing annual data on direct and portfolio investment positions of inverted companies and on their primary income balance;
  - publishing information on retained earnings of the new parent companies.
- Paragraph 20: Such presentations would remain supplemental and at the discretion of the reporting economy, as in BPM6, depending on significance and availability of information on corporate structures and operations.

### Scope of supplemental presentations and related corporate actions
- Paragraph 21: Supplemental presentations might also cover other forms of corporate restructuring with similar economic effects, such as changes in residence under BPM6, paragraph 4.167.
  - The economic substance of changes in residence (BPM6, paragraph 4.167) and changes in residence resulting from corporate inversions are similar despite differences in recording: “other changes in volume” for the former versus “financial transactions” for the latter.
  - Compilers may judge whether to include both forms in supplemental presentations based on relevance in their jurisdiction.

### Consultation, typology, and task team feedback
- Paragraph 22: The Globalization Task Team (GZTT) was consulted in November 2021 on the proposed definition and typology.
  - A slight majority of the GZTT agreed with the proposed definition; a few members felt that including “that is the ultimate parent of the corporate group” could cause confusion but it limits the definition to cases involving the ultimate parent.
  - The GZTT agreed the typology was useful; some suggestions for clarifying the typology were adopted in the final Guidance Note (GN).
- Footnote observation: Professional judgment may be required to assess whether reallocation of operational headquarters or operations of a purely administrative nature involving only the change of International Securities Identification Number fall under the definition of corporate inversion.

### Committee decision at February 2021 meeting
- Paragraph 24: The IMF Committee on Balance of Payments Statistics supported the need for an official definition of corporate inversion for statistical purposes in the updated BPM6.
  - The Committee found a full typology of corporate actions useful (or at least the most usual cases) indicating whether actions should be treated as transactions or as other changes in volume (OCV).
  - The Committee agreed with a voluntary supplemental data collection on corporate inversions for countries where this may be important and proposed further guidance for compilers in the BPM7 Compilation Guide.
  - The Committee suggested the DITT consult with the GZTT in finalizing the Guidance Note; the current GN version incorporates these discussions.

### Recommendations
- Paragraph 23: Recommended actions:
  - Include in BPM7 a taxonomy of the most usual cases of corporate actions that involve inversions or other forms of restructuring with similar economic effects (as outlined in paragraph eight).
  - Include in BPM7 the official definition of corporate inversion as in paragraph 19.
  - Strengthen guidance on publishing supplementary detail on corporate inversions; examples of supplemental presentations include annual data on:
    - direct and portfolio investment positions of inverted companies,
    - primary income balance of inverted companies,
    - retained earnings of the new parent companies.
  - Maintain these presentations as supplemental and at the discretion of the reporting economy.

### Rejected alternatives
- Paragraph 25: Alternative A1 was rejected because additional guidance is needed on identifying inversions and on the types of statistics useful to policymakers and analysts.
- Paragraph 26: Alternative A3 was rejected because the practical solution offered does not address the conceptual question of whether an international transaction should be considered to have occurred, and implementation would be difficult because both sides of the transaction typically would not be covered by portfolio investment statistics.

### BPM6 guidance excerpt (paragraphs 8.19–8.22) — key points retained in recommendation
- Paragraph 8.19: Corporate inversion is corporate restructuring whereby the original parent becomes a subsidiary of a new parent in another economy; ownership of a group of enterprises may be shifted to the new parent. Inversion is achieved by transactions in assets between different entities and is recorded as financial transactions.
- Paragraph 8.20: Operational structure and ultimate shareholders remain effectively unchanged, but the new parent benefits from the taxation and regulatory environment of its economy of incorporation; inversions can involve large financial-account values with little or no movement in resources, motivating interest in separating them from other direct investment. Supplementary data could be provided if not prevented by confidentiality.
- Paragraph 8.21: Accounting treatment: assets of the original parent are treated as returned to shareholders through withdrawal of equity and then reinvested in the new parent at the same value — a rearrangement of balance sheets through equality-valued equity transactions in the financial account (may include both portfolio and direct investment).
- Paragraph 8.22: Assets may be shifted between enterprises because of restructuring; as with other stock swaps, owners sell securities in the first enterprise and buy securities in the second enterprise (financial account entries, not capital transfers or other changes).

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_Source: https://www.imf.org/-/media/files/data/statistics/bpm6/approved-guidance-notes/d4-corporate-inversions.pdf_