## SECTION I: THE ISSUE

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### Background: definition, features, and geographic incidence
- Definition: A “corporate inversion” is when some multinational enterprises (MNEs) geographically locate (or re-locate) their economy of legal residence to reduce their global tax liability. The inversion strategy often involves an agreement between corporations in two countries where a corporation (“the inverter”) merges with a corporation (“the new foreign parent company”) headquartered in a lower-tax economy, typically via an exchange of shares and an agreement to designate the lower-tax economy as the legal residence of the combined entity.
- Typical features:
  - Usually no change in the geographical allocation of headquarter functions; at most some or a few board meetings occur in the new foreign parent company’s economy.
  - Generally, a direct investment 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 convert to shares in the new foreign parent company.
- Geographic incidence:
  - The United States accounted for only 21 percent of the dollar value of a large sample of inversions in OECD countries (Col et al. (2019)).
  - Other important home countries include Australia, Canada, France, Germany, Italy, Netherlands, Spain, Sweden, Switzerland, and the United Kingdom.

### Material macroeconomic effects (examples and estimates)
- Fitzgerald (2015) estimates undistributed profits of resident corporate inversions in 2014 were 6.9 billion euro, representing 11.0 percent of Ireland’s primary income receipts in that year.
- Nelisse and Hiemstra (2019) estimate resident corporate inversions contributed 9.1 billion euro to Netherlands’ primary income balance in 2017, representing 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 direct investment equity position in the United States.
- For Italy, corporate inversion has remained relevant and has not diminished over time; various Italian MNEs have relocated their economy of legal residence abroad, usually to the Netherlands (Federico et al. (2018)).

### Accounting and statistical implications
- For an exchange-of-shares inversion, the inverting company essentially pays a liquidating dividend to its shareholders, who then make a portfolio investment in the new foreign parent company at the same value; the new foreign parent company uses these funds to make a direct investment in the inverting company.
- Corporate inversions are not covered in the OECD Benchmark Definition of Foreign Direct Investment, fourth edition, 2008 (BD4).
- Under current guidance, the different treatment of reinvested earnings on direct investment and portfolio investment will tend to reduce net primary income receipts and higher-level aggregates derived from them—corporate profits and total gross national income.
- BPM6, paragraph 8.20 notes inversions can involve large financial-account values with little or no movement in resources and encourages supplementary data if not prevented by confidentiality.

### Identification and classification challenges
- Difficulties exist in defining and identifying all types of restructuring that constitute inversions.
- Cortes et al. (2015) identify three classes for U.S. companies:
  - (i) Pure inversion: create a foreign entity as legal head office while keeping HQ functions in the original economy;
  - (ii) Restructuring inversion: become foreign-owned through merger, leveraged buy-out, bankruptcy, or spin-off;
  - (iii) Born inverted: a new domestic company is established along with a foreign entity as owner while HQ functions remain in the original economy.
- Corporate inversions mainly involve listed groups, so public information (company press releases, reports) is often available, but complex restructurings can still challenge compilers.
- Conceptual questions arise about whether subsequent acquisitions by the new foreign parent of domestic companies in the inverter’s economy should be treated as inversion-related and whether a new foreign parent might over time act like a real HQ.

### Issues for Discussion — Alternatives for Statistical Treatment
- Alternative 1 (A1) — Status quo:
  - Maintain current methodological and presentational treatment (no separate identification/presentation).
  - Rationale: definition precision and trackability concerns; confidentiality constraints; a small number of affected countries.
  - Suggestion: countries hosting inversion-related DI might quantify activity within Activities of Multinational Enterprises (AMNE) statistics, but no balance-of-payments special treatment recommended.
- Alternative 2 (A2) — Strengthen guidance and publish supplementary detail:
  - Strengthen BPM6 guidance on publishing supplementary detail and provide a richer description of corporate inversions.
  - Rationale: inversion-related DI differs in motivation and impacts from traditional DI and tends to involve large financial-account values with little or no resource movement (BPM6, para. 8.20); supplemental statistics improve interpretability without changing aggregates.
  - Identification could use objective criteria (Anknüpfungspunkte), examples 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 most strongly affected by the activities of the corporation (e.g., geographic center of the corporate global labor force).
  - Additional approaches:
    - Eurostat’s “Global Decision Centre” concept designates where the “true” center of control resides.
    - Statistics Netherlands defined inversions with new home countries in the Netherlands as those that (i) were born and undertook initial growth stages abroad and (ii) had a relatively limited share of global activities in the Netherlands (Nelisse and Hiemstra (2019)).
  - Relation to ultimate investing economy statistics: a tighter relation could be achieved if both sets of statistics follow a similar control approach (“winner takes all”).
  - Treatment of subsequent domestic acquisitions by the new foreign parent: one option is that once a false foreign parent is identified, all subsequent acquisitions in the inverter’s economy are inversion-related.
  - Confidentiality management: present inversion statistics at less geographic detail, positions only, and/or lower frequency; encouraged for economies with significant inversion-related DI.
- Alternative 3 (A3) — Record inversions as portfolio investment:
  - Rationale: the new foreign parent typically does not supply additional contributions such as know-how, technology, management, and marketing (BPM6, paragraph 6.4); transactions are primarily financial engineering.
  - Consequence: record as portfolio rather than direct investment, leading to largely offsetting portfolio investment flows as flows that would have been DI under current guidelines are recorded as portfolio investment.
  - Practical/legal question: whether the new foreign parent is a separate institutional unit if it lacks significant presence (similar to SPEs, near-SPEs).
  - Implementation difficulty: both sides of the transaction typically would not be covered by portfolio investment statistics.

### Outcomes — DITT Recommendation and Practical Guidance
- Consensus:
  - The Direct Investment Task Team (DITT) supports Alternative 2 (A2).
- Reasons for A2:
  - Corporate inversions reduce the analytical usefulness of direct investment statistics because they are motivated by factors other than those conventionally ascribed to direct investors (BPM6, paragraph 6.4).
  - Practical identification challenges are acknowledged but considered manageable with supplementary guidance and compiler judgment.
- Proposed definition:
  - Adopt the definition referenced in BPM6, paragraph 8.19: “A corporate inversion describes the corporate restructuring of a transnational enterprise group such that the original parent company in one economy 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.”
  - Additional guidance from BPM6 paragraphs 8.19–8.22 and academic studies (e.g., Cortes, Gomes, and Gopalan (2015)) should inform implementation; Annex III of the note summarizes academic definitions.
- Practical presentation recommendations:
  - Compilers will need expert judgment to identify inversions; data confidentiality challenges can be managed by:
    - Publishing data at higher levels of geographic aggregation and/or at lower frequency (e.g., annual).
    - Publishing annual data on direct and portfolio investment positions of inverted companies and on their primary income balance to assess home and host effects.
    - Publishing information on retained earnings of new parent companies because of asymmetric treatment of reinvested earnings under portfolio and direct investment.
  - Presentations would remain supplemental and at the discretion of the reporting economy based on the significance of inversions and data availability.

### Rejected Alternatives and rationale
- Rejected A1:
  - Rationale: additional guidance is needed on identifying inversions and on the types of supplemental statistics useful to policymakers and analysts.
- Rejected A3:
  - Rationale: does not resolve the conceptual question of whether an international transaction occurred and is difficult to implement because both sides of transactions typically would not be captured within portfolio investment statistics.

### Questions for Discussion
- 1. Do you feel that corporate inversions have degraded the analytical usefulness of direct investment statistics, and key national accounting aggregates like corporate profits and gross national income?
- 2. Do you agree that an official definition of corporate inversion, for example, for statistical or fiscal purposes is needed?
- 3. Do you agree with the definition proposed in paragraph 18?
- 4. Do you agree that countries for which this is an important phenomenon and with a clear definition to guide compilers, should produce supplemental statistics on corporate inversions?

### Annex II. Excerpt from Hanson et al. (2015): Effects and guidance
- Effects of inversions on national income and product accounts (NIPAs):
  - Inversions affect select aggregates of the national income and product accounts (NIPAs), most notably:
    - income receipts from the rest of the world
    - income payments to the rest of the world
    - NIPA aggregates derived from these data—corporate profits and gross national income.
  - Gross national income (GNI) is reduced by inversions: "gross national income, that is, income resulting from the current production of goods and services by U.S.-owned labor and capital."
  - Corporate profits are reduced via a decrease in net profit receipts from the rest of the world, where net profit receipts = profit receipts from the rest of the world less profit payments to the rest of the world.
  - Mechanism described:
    - The introduction of a new foreign owner generates a payment to the rest of the world in the form of direct investment income on equity that includes the worldwide profits of the inverting corporation.
    - This payment may be offset partially by dividends paid by the new foreign corporation to its U.S. shareholders, some of whom may be former shareholders in the U.S. corporation that inverted.
    - Because corporations rarely pay dividends equal to, or more than, their total current earnings, the inversion’s effect on profit payments to the rest of the world would typically be greater than its effect on profit receipts from the rest of the world, and therefore the effect on net profit receipts from rest of the world would be negative.
  - The issue is being discussed separately under the Financial and Payments Systems Task Team guidance note F.2.

- Characteristics of inverted corporations (selected academic studies):
  - Cross-study indicators reported for inverted firms include:
    - New parent company located in a foreign economy
    - New parent company located in a foreign economy with lower tax rate
    - Listed on the stock exchange of old parent company's home economy
    - Follows securities laws of old parent company's home economy
    - Retains management and control functions of the global corporation
    - Location of the majority of the firm's shareholders
  - Presence of markers by study (as indicated by "x" in the source table):
    - Cortes, Gomes, Gopalan (2014): x x x x x
    - Rao (2015): x x
    - Webber (2011): x x x
    - Voget (2011): x x

- BPM6 guidance on corporate inversions (paragraphs 8.19–8.22):
  - Definition and mechanics (paragraph 8.19):
    - "Corporate inversion describes the corporate restructuring of a transnational enterprise group such that the original parent company in one economy becomes a subsidiary of the new parent in another economy."
    - Ownership of a group of enterprises may be shifted to the new parent company; arrangements also called corporate relocations, headquarters relocations, or corporate restructuring.
    - Inversion may take place over more than one period.
    - Inversion is similar in economic effect to a change of residence of the parent company, but differs because inversion is achieved by transactions in assets between different entities rather than by a single entity changing its residence.
    - Corporate inversion results in financial transactions being recorded in the financial account; some other restructuring may involve other changes in volume, for example, the appearance or disappearance of entities.
  - Analytical and data considerations (paragraph 8.20):
    - The economy of the direct investor is changed by corporate inversion while operational structure and ultimate shareholders remain effectively unchanged.
    - The new parent company benefits from the taxation and regulatory environment of its economy of incorporation.
    - Because inversions can involve large values in the financial account 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.
  - Accounting treatment in the financial account (paragraph 8.21):
    - Assets of the original parent are treated as having been returned to the shareholders of the parent company through the withdrawal of equity and then reinvested in the new parent company at the same value.
    - This is a rearrangement of balance sheets through transactions in equity in the financial account of equal value with no change in net lending or borrowing. (Entries may include both portfolio and direct investment.)
    - With some forms of restructuring, the direct investment enterprises of the old parent may become the direct investment enterprises of the new one.
  - Asset shifts and recording (paragraph 8.22):
    - Assets may be shifted from one enterprise to a second enterprise because of restructuring within an enterprise group.
    - As with other stock swaps, the owners are selling securities in the first enterprise and buying securities in the second enterprise.
    - These are financial account entries, not capital transfers or other changes.

*Direct Investment Task Team (DITT), International Monetary Fund (IMF).*

### SECTION I: THE ISSUE

### SECTION I: THE ISSUE

### Background

- Definition: A “corporate inversion” is when some multinational enterprises (MNEs) geographically locate (or re-locate) their economy of legal residence to reduce their global tax liability. The inversion strategy often involves an agreement between corporations in two countries where a corporation (“the inverter”) merges with a corporation (“the new foreign parent company”) headquartered in a lower-tax economy, typically via an exchange of shares and an agreement to designate the lower-tax economy as the legal residence of the combined entity.
- Typical features:
  - Usually no change in the geographical allocation of headquarter functions; at most some or a few board meetings occur in the new foreign parent company’s economy.
  - Generally, a direct investment 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 convert to shares in the new foreign parent company.
- Geographic incidence:
  - The United States accounted for only 21 percent of the dollar value of a large sample of inversions in OECD countries (Col et al. (2019)).
  - Other important home countries include Australia, Canada, France, Germany, Italy, Netherlands, Spain, Sweden, Switzerland, and the United Kingdom.
- Material macroeconomic effects (examples and estimates):
  - Fitzgerald (2015) estimates undistributed profits of resident corporate inversions in 2014 were 6.9 billion euro, representing 11.0 percent of Ireland’s primary income receipts in that year.
  - Nelisse and Hiemstra (2019) estimate resident corporate inversions contributed 9.1 billion euro to Netherlands’ primary income balance in 2017, representing 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 direct investment equity position in the United States.
  - For Italy, corporate inversion has remained relevant and has not diminished over time; various Italian MNEs have relocated their economy of legal residence abroad, usually to the Netherlands (Federico et al. (2018)).
- Accounting and statistical implications:
  - For an exchange-of-shares inversion, the inverting company essentially pays a liquidating dividend to its shareholders, who then make a portfolio investment in the new foreign parent company at the same value; the new foreign parent company uses these funds to make a direct investment in the inverting company.
  - Corporate inversions are not covered in the OECD Benchmark Definition of Foreign Direct Investment, fourth edition, 2008 (BD4).
  - Under current guidance, the different treatment of reinvested earnings on direct investment and portfolio investment will tend to reduce net primary income receipts and higher-level aggregates derived from them—corporate profits and total gross national income.
  - BPM6, paragraph 8.20 notes inversions can involve large financial-account values with little or no movement in resources and encourages supplementary data if not prevented by confidentiality.
- Identification and classification challenges:
  - Difficulties exist in defining and identifying all types of restructuring that constitute inversions.
  - Cortes et al. (2015) identify three classes for U.S. companies:
    - (i) Pure inversion: create a foreign entity as legal head office while keeping HQ functions in the original economy;
    - (ii) Restructuring inversion: become foreign-owned through merger, leveraged buy-out, bankruptcy, or spin-off;
    - (iii) Born inverted: a new domestic company is established along with a foreign entity as owner while HQ functions remain in the original economy.
  - Corporate inversions mainly involve listed groups, so public information (company press releases, reports) is often available, but complex restructurings can still challenge compilers.
  - Conceptual questions arise about whether subsequent acquisitions by the new foreign parent of domestic companies in the inverter’s economy should be treated as inversion-related and whether a new foreign parent might over time act like a real HQ.

### Issues for Discussion — Alternatives for Statistical Treatment

- Alternative 1 (A1) — Status quo:
  - Maintain current methodological and presentational treatment (no separate identification/presentation).
  - Rationale: definition precision and trackability concerns; confidentiality constraints; a small number of affected countries.
  - Suggestion: countries hosting inversion-related DI might quantify activity within Activities of Multinational Enterprises (AMNE) statistics, but no balance-of-payments special treatment recommended.

- Alternative 2 (A2) — Strengthen guidance and publish supplementary detail:
  - Strengthen BPM6 guidance on publishing supplementary detail and provide a richer description of corporate inversions.
  - Rationale: inversion-related DI differs in motivation and impacts from traditional DI and tends to involve large financial-account values with little or no resource movement (BPM6, para. 8.20); supplemental statistics improve interpretability without changing aggregates.
  - Identification could use objective criteria (Anknüpfungspunkte), examples 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 most strongly affected by the activities of the corporation (e.g., geographic center of the corporate global labor force).
  - Additional approaches:
    - Eurostat’s “Global Decision Centre” concept designates where the “true” center of control resides.
    - Statistics Netherlands defined inversions with new home countries in the Netherlands as those that (i) were born and undertook initial growth stages abroad and (ii) had a relatively limited share of global activities in the Netherlands (Nelisse and Hiemstra (2019)).
  - Relation to ultimate investing economy statistics: a tighter relation could be achieved if both sets of statistics follow a similar control approach (“winner takes all”).
  - Treatment of subsequent domestic acquisitions by the new foreign parent: one option is that once a false foreign parent is identified, all subsequent acquisitions in the inverter’s economy are inversion-related.
  - Confidentiality management: present inversion statistics at less geographic detail, positions only, and/or lower frequency; encouraged for economies with significant inversion-related DI.

- Alternative 3 (A3) — Record inversions as portfolio investment:
  - Rationale: the new foreign parent typically does not supply additional contributions such as know-how, technology, management, and marketing (BPM6, paragraph 6.4); transactions are primarily financial engineering.
  - Consequence: record as portfolio rather than direct investment, leading to largely offsetting portfolio investment flows as flows that would have been DI under current guidelines are recorded as portfolio investment.
  - Practical/legal question: whether the new foreign parent is a separate institutional unit if it lacks significant presence (similar to SPEs, near-SPEs).
  - Implementation difficulty: both sides of the transaction typically would not be covered by portfolio investment statistics.

### Outcomes — DITT Recommendation and Practical Guidance

- Consensus:
  - The Direct Investment Task Team (DITT) supports Alternative 2 (A2).
- Reasons for A2:
  - Corporate inversions reduce the analytical usefulness of direct investment statistics because they are motivated by factors other than those conventionally ascribed to direct investors (BPM6, paragraph 6.4).
  - Practical identification challenges are acknowledged but considered manageable with supplementary guidance and compiler judgment.
- Proposed definition:
  - Adopt the definition referenced in BPM6, paragraph 8.19: “A corporate inversion describes the corporate restructuring of a transnational enterprise group such that the original parent company in one economy 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.”
  - Additional guidance from BPM6 paragraphs 8.19–8.22 and academic studies (e.g., Cortes, Gomes, and Gopalan (2015)) should inform implementation; Annex III of the note summarizes academic definitions.
- Practical presentation recommendations:
  - Compilers will need expert judgment to identify inversions; data confidentiality challenges can be managed by:
    - Publishing data at higher levels of geographic aggregation and/or at lower frequency (e.g., annual).
    - Publishing annual data on direct and portfolio investment positions of inverted companies and on their primary income balance to assess home and host effects.
    - Publishing information on retained earnings of new parent companies because of asymmetric treatment of reinvested earnings under portfolio and direct investment.
  - Presentations would remain supplemental and at the discretion of the reporting economy based on the significance of inversions and data availability.

### Rejected Alternatives

- Rejected A1:
  - Rationale: additional guidance is needed on identifying inversions and on the types of supplemental statistics useful to policymakers and analysts.
- Rejected A3:
  - Rationale: does not resolve the conceptual question of whether an international transaction occurred and is difficult to implement because both sides of transactions typically would not be captured within portfolio investment statistics.

### Questions for Discussion

- 1. Do you feel that corporate inversions have degraded the analytical usefulness of direct investment statistics, and key national accounting aggregates like corporate profits and gross national income?
- 2. Do you agree that an official definition of corporate inversion, for example, for statistical or fiscal purposes is needed?
- 3. Do you agree with the definition proposed in paragraph 18?
- 4. Do you agree that countries for which this is an important phenomenon and with a clear definition to guide compilers, should produce supplemental statistics on corporate inversions?

*Source: Direct Investment Task Team (DITT), International Monetary Fund (IMF).*

### Annex II. Excerpt from Hanson et al. (2015)

### Annex II. Excerpt from Hanson et al. (2015)

### Effects of inversions on national income and product accounts (NIPAs)
- Inversions affect select aggregates of the national income and product accounts (NIPAs), most notably:
  - income receipts from the rest of the world
  - income payments to the rest of the world
  - NIPA aggregates derived from these data—corporate profits and gross national income.
- Gross national income (GNI) is reduced by inversions: "gross national income, that is, income resulting from the current production of goods and services by U.S.-owned labor and capital."
- Corporate profits are reduced via a decrease in net profit receipts from the rest of the world, where net profit receipts = profit receipts from the rest of the world less profit payments to the rest of the world.
- Mechanism described:
  - The introduction of a new foreign owner generates a payment to the rest of the world in the form of direct investment income on equity that includes the worldwide profits of the inverting corporation.
  - This payment may be offset partially by dividends paid by the new foreign corporation to its U.S. shareholders, some of whom may be former shareholders in the U.S. corporation that inverted.
  - Because corporations rarely pay dividends equal to, or more than, their total current earnings, the inversion’s effect on profit payments to the rest of the world would typically be greater than its effect on profit receipts from the rest of the world, and therefore the effect on net profit receipts from rest of the world would be negative.
- The issue is being discussed separately under the Financial and Payments Systems Task Team guidance note F.2.

### Characteristics of inverted corporations (selected academic studies)
- Cross-study indicators reported for inverted firms include (as tabulated across studies):
  - New parent company located in a foreign economy
  - New parent company located in a foreign economy with lower tax rate
  - Listed on the stock exchange of old parent company's home economy
  - Follows securities laws of old parent company's home economy
  - Retains management and control functions of the global corporation
  - Location of the majority of the firm's shareholders
- Presence of markers by study (as indicated by "x" in the source table):
  - Cortes, Gomes, Gopalan (2014): x x x x x
  - Rao (2015): x x
  - Webber (2011): x x x
  - Voget (2011): x x

### BPM6 guidance on corporate inversions (paragraphs 8.19–8.22)
- Definition and mechanics (paragraph 8.19):
  - "Corporate inversion describes the corporate restructuring of a transnational enterprise group such that the original parent company in one economy becomes a subsidiary of the new parent in another economy."
  - Ownership of a group of enterprises may be shifted to the new parent company; arrangements also called corporate relocations, headquarters relocations, or corporate restructuring.
  - Inversion may take place over more than one period.
  - Inversion is similar in economic effect to a change of residence of the parent company, but differs because inversion is achieved by transactions in assets between different entities rather than by a single entity changing its residence.
  - Corporate inversion results in financial transactions being recorded in the financial account; some other restructuring may involve other changes in volume, for example, the appearance or disappearance of entities.
- Analytical and data considerations (paragraph 8.20):
  - The economy of the direct investor is changed by corporate inversion while operational structure and ultimate shareholders remain effectively unchanged.
  - The new parent company benefits from the taxation and regulatory environment of its economy of incorporation.
  - Because inversions can involve large values in the financial account 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.
- Accounting treatment in the financial account (paragraph 8.21):
  - Assets of the original parent are treated as having been returned to the shareholders of the parent company through the withdrawal of equity and then reinvested in the new parent company at the same value.
  - This is a rearrangement of balance sheets through transactions in equity in the financial account of equal value with no change in net lending or borrowing. (Entries may include both portfolio and direct investment.)
  - With some forms of restructuring, the direct investment enterprises of the old parent may become the direct investment enterprises of the new one.
- Asset shifts and recording (paragraph 8.22):
  - Assets may be shifted from one enterprise to a second enterprise because of restructuring within an enterprise group.
  - As with other stock swaps, the owners are selling securities in the first enterprise and buying securities in the second enterprise.
  - These are financial account entries, not capital transfers or other changes.

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