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OXFAM METHODOLOGY

NOVEMBER 2017

ASSESSING JURISDICTIONS

AGAINST EU LISTING CRITERIA

Oxfam methodology

In 2016, the EU started a three-phase process to list corporate tax havens based on

three sets of criteria: transparency, fair taxation, and the implementation of anti-

BEPS (i.e. base erosion and profit shifting) measures. The Council of the EU is

currently assessing 92 jurisdictions according to these criteria and aims to release

the final list by the end of 2017.

Oxfam has

used the EU’s

three criteria and assessed the 92 jurisdictions as well as

EU countries. This note explains the methodology for that process. The Oxfam

briefing

Blacklist or Whitewash?

presents a

‘shadow

blacklist’ that can be used as a

source of reference when the EU publishes its own blacklist. In addition, as the EU

has decided to blacklist only third countries, Oxfam argues that a global blacklist of

corporate tax havens should also include EU countries and countries that are

engaged in dialogue with the EU on taxation.

EMBARGOED UNTIL

23:01

HRS CET TUESDAY 27 NOVEMBER 2017

For more information, or to comment on this paper, email

[email protected]

www.oxfam.org

EUU, Alm.del - 2017-18 - Bilag 182: Henvendelse af 29/11-17 fra Oxfam IBIS om sortlistning af skattely

INTRODUCTION

In 2016, the EU started a three-phase process to list corporate tax havens based on three

sets of criteria: transparency, fair taxation, and the implementation of anti-BEPS (i.e. base

erosion and profit shifting) measures. The Council of the EU is currently assessing 92

jurisdictions

according to these criteria and aims to release the final list by the end of

2017, around the final meeting of the year of the Economic and Financial Affairs Council

(ECOFIN).

For the briefing

Blacklist or Whitewash?

Oxfam used the EU’s

three criteria and assessed

the same 92 jurisdictions as well as EU countries. This note explains the methodology for

that process. The result of that exercise is a

‘shadow

blacklist’ that can be used as a

source of reference when the EU publishes its own blacklist. In addition, as the EU has

decided to blacklist only third countries, Oxfam points out that a global blacklist of

corporate tax havens should also include EU countries and countries that are engaged in

‘dialogue’ with the EU on taxation.

Below is a more detailed description of each criterion and how Oxfam applied it.

Note 1:

For a consequent number of jurisdictions, and especially among the ones identified

as tax havens by Oxfam in its report

Tax battles,

relevant data are unavailable. This is

particularly the case for revenues of intellectual property, interests and dividends (e.g.

limited data are available for Barbados). This absence of data in international databases

should raise questions, especially on the willingness of those jurisdictions lacking data

(often well-known tax havens) to be really transparent. Indeed, many of those jurisdictions

claim not to be a tax havens, as they are participating in international fora on exchange of

information. However, they are not publishing all the basic economic data.

Note 2:

The EU indicated in its criteria its willingness to give a specific treatment to

developing countries. Oxfam took that element into account when assessing countries, first

indicating countries being low- and middle-income countries,

and secondly considering

their performance in the quantitative analysis. For that reason, low- and middle-income

countries which are solely failing the transparency and BEPS criteria do not feature in the

final list unless they are recognized as financial centres (Malaysia, Marshall Islands, Nauru,

Niue, Palau, Panama, Vanuatu

–

countries considered to be financial centres) or are EU

candidate Member States, OECD members or G20 members.

Note 3:

In 2016,

Oxfam assessed about 50 risky jurisdictions, taking into account a

broader set of indicators on harmful tax practices.

The aim of Oxfam’s exercise was to

identify the world’s worst

tax havens.

The results can be found in Oxfam’s report

Tax

Battles

, for which Oxfam assessed a number of harmful tax regimes (including excess profit

rulings, patent boxes and others).

Note 4:

Oxfam worked with the assumption that the EU should keep countries on the

blacklist until they have taken concrete steps towards abolishing their harmful tax

measures and stopped facilitating offshore structures.

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Scoring on criterion 1: Tax transparency criteria

Box 1: EU tax transparency criteria

Criteria that a jurisdiction should fulfil in order to be considered compliant on tax

transparency:

1.1. Initial criterion with respect to the OECD Automatic Exchange of Information

(AEOI) standard (the Common Reporting Standard

–

CRS): the jurisdiction should

have committed to and started the legislative process to implement the CRS

effectively, with first exchanges in 2018 (with respect to the year 2017) at the latest

and have arrangements in place to be able to exchange information with all Member

States, by the end of 2017,

either by signing the Multilateral Competent Authority

Agreement (MCAA) or through bilateral agreements;

Future criterion with respect to the CRS as from 2018: the jurisdiction, should possess

at least a

‘Largely

Compliant’ rating by the Global Forum with respect to the AEOI

CRS.

1.2. the jurisdiction should possess at least a

‘Largely

Compliant’ rating by the Global

Forum with respect to the OECD Exchange of Information on Request (EOIR)

standard, with due regard to the fast track procedure, and

1.3. (for sovereign states) the jurisdiction should have either: i) ratified, agreed to

ratify, be in the process of ratifying, or committed to the entry into force, within a

reasonable time frame, of the OECD Multilateral Convention on Mutual Administrative

Assistance (MCMAA) in Tax Matters, as amended, or ii) a network of exchange

arrangements in force by 31 December 2018 which is sufficiently broad to cover all

Member States, effectively allowing both EOIR and AEOI; (for non-sovereign

jurisdictions) the jurisdiction should either: i) participate in the MCMAA, as amended,

which is either already in force or expected to enter into force for them within a

reasonable timeframe, or ii) have a network of exchange arrangements in force, or

have taken the necessary steps to bring such exchange agreements into force within

a reasonable timeframe, which is sufficiently broad to cover all Member States,

allowing both EOIR and AEOI.

1.4 Future criterion: in view of the initiative for future global exchange of beneficial

ownership information, the aspect of beneficial ownership will be incorporated at a

later stage as a fourth transparency criterion for screening.

Until 30 June 2019, the following exception should apply: A jurisdiction could be

regarded as compliant on tax transparency if it fulfils at least two of the criteria 1.1, 1.2

or 1.3. This exception does not apply to the jurisdictions which are rated

‘Non-

Compliant’ on criterion 1.2 or which have not obtained at least

‘Largely

Compliant’

rating on that criterion by 30 June 2018.

In line with the EU’s ‘tax transparency criteria’ (see

Box 1), Oxfam assessed countries on:

•

1.1 Commitment to, and start of legislative process to, effectively implement the CRS;

1.2 Having at least a largely compliant rating by the Global Forum with respect to the

OECD Exchange of Information on Request (EOIR) standard;

1.3 Commitment to the OECD Multilateral Convention on Mutual Administrative

Assistance.

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Until 2019, the EU criteria rule that a jurisdiction should be regarded as compliant on tax

transparency, if it fulfils at least two of the above criteria. However, this exception does not

apply to all jurisdictions which are rated non-compliant on criterion 1.2.

After applying this, Oxfam found 13

jurisdictions to be failing the EU’s tax transparency

criteria. Those countries are:

Antigua and Barbuda

Bosnia and Herzegovina

Former Yugoslav Republic of Macedonia

Guam

Montenegro

New Caledonia

Oman

Palau

Serbia

Taiwan

Trinidad and Tobago

US Virgin Islands

Vanuatu

Note on the USA:

The USA has implemented its own Foreign Account Tax Compliance

Act (FATCA) legislation rather than signing up to the OECD standards on the automatic

exchange of tax information and the Common Reporting Standard (CRS). However, the EU

tax transparency criteria were drafted in such way to avoid the United States being

blacklisted, notably by delaying the obligation to comply with all three sub-criteria to 2019.

Scoring on criteria 2: Fair taxation

Box 2: EU fair taxation criteria

–

criteria that a jurisdiction should fulfil in order

to be considered compliant on fair taxation

2.1.

The jurisdiction should have no preferential tax measures that could be regarded

as harmful according to the criteria set out in the Resolution of the Council and the

Representatives of the Governments of the Member States, meeting within the

Council of 1 December 1997 on a code of conduct for business taxation (see below),

and

2.2.

The jurisdiction should not facilitate offshore structures or arrangements aimed at

attracting profits which do not reflect real economic activity in the jurisdiction.

Clarification on 2.1: Code of Conduct on Business Taxation (1997)

When assessing whether such measures are harmful, account should be taken of,

inter alia:

1. Whether advantages are accorded only to non-residents or in respect of

transactions carried out with non-residents, or

2. Whether advantages are ring-fenced from the domestic market, so they do not

affect the national tax base, or

3. Whether advantages are granted even without any real economic activity and

substantial economic presence within the Member State offering such tax

advantages, or

4. Whether the rules for profit determination in respect of activities within a

multinational group of companies departs from internationally accepted principles,

notably the rules agreed upon within the OECD, or

5. Whether the tax measures lack transparency, including where legal provisions are

relaxed at administrative level in a non-transparent way.

Clarification on 2.2: Council of the EU (20 February 2017)

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1. For the purposes of application of criterion 2.2, the absence of a corporate tax or

applying a nominal corporate tax rate equal to zero or almost zero by a jurisdiction

should be regarded as within the scope of Paragraph A of the Code of Conduct for

Business Taxation of 1 December 1997 (Code of Conduct).

2. In this respect, where criterion 2.1 is inapplicable solely due to the fact that the

jurisdiction concerned does not meet the gateway criterion under Paragraph B of

the Code of Conduct, because of the ‘absence of a corporate tax system or

applying a nominal corporate tax rate equal

to zero or almost zero’, then the five

factors identified in paragraph B of the Code of Conduct should be applied by

analogy to assess whether the criterion 2.2 has been met.

3. In the context of criterion 2.2 the fact of absence of a corporate tax or applying a

nominal corporate tax rate equal to zero or almost zero cannot alone be a reason

for concluding that a jurisdiction does not meet the requirements of criterion 2.2.

4. A jurisdiction should be deemed as non-compliant with criterion 2.2 if it refuses to

engage in a meaningful dialogue or does not provide the information or

explanations that the Code of Conduct Group may reasonably require or otherwise

does not cooperate with the Code of Conduct Group where it needs to ascertain

compliance of that jurisdiction with criterion 2.2 in the conduct of the screening

process.

Source: Council of the EU (2016) Criteria and process leading to the establishment of the EU list of non-

cooperative jurisdictions for tax purposes - 14166/16, http://data.consilium.europa.eu/doc/document/ST-

14166-2016-INIT/en/pdf

Oxfam assessed both the 92 jurisdictions identified by the EU and EU member states,

staying as close as possible to the EU’s

criteria on fair taxation (see Box 2).

It is important to note that the EU did not disclose an exact methodology

for how it intends

to assess

‘Whether

advantages are granted even without any real economic activity and

substantial economic presence within the Member State offering such tax advantages’;

therefore, Oxfam used a series of common indicators exposing strong evidence of base

erosion and profit shifting as described below. To ensure that economic indicators used in

this assessment only capture countries granting tax advantages even without any real

economic activity in that country, Oxfam used high and conservative thresholds. Thus,

Oxfam only identified countries that should certainly be on the final EU list. Some

territories, such as Guernsey or the Isle of Man, scored just below the thresholds. The EU

has more access to economic information and is in direct contact with the countries

assessed, so could compile a list which includes those jurisdictions as well. If the EU had

more information than that publicly available, and which would lead to other jurisdictions

being listed, Oxfam would welcome that development.

Oxfam assessed the fair taxation criteria as follows.

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2.1 Assessment of countries on having preferential tax measures that could be

regarded as harmful according to the criteria set out by EU

According to the European Commission Scoreboard and difference assessment of

potential harmful tax by the OECD, Oxfam found that 73 countries should be assessed.

Andorra

Antigua and Barbuda

Armenia

Aruba

Australia

Barbados

Belgium

Belize

Botswana

Brazil

Cabo Verde

Canada

Chile

China

China, Hong Kong SAR

China, Macao SAR

Colombia

Cook Islands

Costa Rica

Curaçao

Dominica

Fiji

France

Georgia

Greece

Grenada

Hungary

India

Indonesia

Ireland

Israel

Italy

Jamaica

Japan

Jordan

Korea, Republic of

Latvia

Liechtenstein

Lithuania

Luxembourg

Malaysia

Maldives

Malta

Mauritius

Montserrat

Morocco

Namibia

Netherlands

Panama

Peru

Portugal

Saint Kitts and Nevis

Saint Lucia

Saint Vincent and the

Grenadines

Samoa

San Marino

Seychelles

Singapore

South Africa

Spain

Switzerland

Taiwan

Thailand

Trinidad and Tobago

Tunisia

Turkey

Turks and Caicos Islands

United Arab Emirates

United Kingdom

United States

Uruguay

US Virgin Islands

Vietnam

2.2 Assessment of countries and whether they facilitate offshore structures or

arrangements aimed at attracting profits which do not reflect real economic activity

in the jurisdiction

In addition, 14 jurisdictions were found to have a 0% tax rate.

According to the EU, 0%

tax rate jurisdictions could represent a risk, and therefore should be assessed to identify

whether they facilitate offshore structures or arrangements.

Anguilla

Bahamas

Bahrain

Bermuda

British Virgin Islands

Cayman Islands

Guernsey

Isle of Man

Jersey

Marshall Islands

Nauru

Palau

Turks and Caicos Islands

Vanuatu

Those 87 jurisdictions in total are then assessed against Paragraph B of the Code of

Conduct Group on Business Taxation, which for paragraph B 3 requires a quantitative

analysis to assess:

‘3.

Whether advantages are granted even without any real economic

activity and substantial economic presence within the Member State (here to be read

‘country’)

offering such tax advantages’.

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Oxfam used different data sets to assess whether profits in a jurisdiction are significantly

out of balance with real economic activity in that jurisdiction.

Indicators

•

The assessment aims to look more closely at the weight of passive income in a

country’s economy. Passive income such as royalties, interests or dividends

are types

of payments which could indicate base erosion and profit shifting if their amount is

disproportionate. Very high outward dividend payments are also an indicator that

disproportionate profits are booked in a jurisdiction.

Similarly, very high inward foreign direct investment

(FDI) relative to a country’s

economy is usually related to offshore structures.

The assessment also considers income from active trade in goods and services,

because profits are sometimes shifted through intra-group trade. Because such

indicators also cover legitimate trade, the thresholds used are particularly high, to

identify only those figures which are disproportionate.

Because of the lack of data available, Oxfam coupled this information with other

indicators from international databases. Where information was missing, Oxfam used

bilateral data reported by partner countries. The lack of comprehensive and reliable

statistics is an issue which needs to be addressed.

•

Thresholds

•

The assessment uses different thresholds, with lower thresholds for more specific

variables.

The broadest income variables are net exports of services to the EU and total exports of

goods to the rest of the world, with correspondingly high thresholds of 50% and 100% of

GDP, respectively. These high thresholds allow countries with legitimate large tourism

or manufacturing exports to be excluded from the listing process. The most specific

variables are net intra-group interest income and net royalty income, for which the

assessment applies a relative threshold of 1% of GDP. For diversified economies,

receiving more than 1% of GDP of such income is a strong indicator of inward profit

shifting. Small island economies are much less diversified, and therefore Oxfam has

also applied an absolute threshold of US$100m for these specific types of income. For

countries with a GDP below US$10bn, such as the Cook Islands, only the absolute

threshold matters.

High levels of royalties, interest and dividend payments were also used as indicators to

identify jurisdictions which are supporting and facilitating offshore structures, so-called

‘conduit tax havens’ which

facilitate offshore economic activity and which might not be

captured by the current EU criteria. The threshold has been set to 2,5% or 5% because

the risk of capturing legitimate trade is low.

•

1 Weight of intellectual property income and royalties

•

Balance of trade in services with EU countries superior to 50% GDP

This includes royalties, but also financial services, management fees, international tourism,

international transport, etc.; which is why the threshold is rather high. Oxfam used partner

country data from Eurostat on the balance of trade in services between EU 28 combined

and each country on the list. While that is not a worldwide total, it is still a good indicator,

and data was available for all jurisdictions except Monaco.

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Using this data, Oxfam identified:

Bermuda 451.2% of GDP

Bahamas 219.9% of GDP

Cayman Islands 136.2% of GDP

•

Level of royalties paid and received above 2.5% of GDP (conduit jurisdiction

assessment)

Using this data, Oxfam identified:

Paid

Ireland 26.48% of GDP

Netherlands 6.41% of GDP

Luxembourg 5.39% of GDP

Malta 4.66% of GDP

2 Weight of interest income

•

Estimated net intra-group interest income more than 1% GDP and more than

US$100m.

Received

Netherlands 5.35% of GDP

Malta 3.03% of GDP

Luxembourg 2.77% of GDP

Ireland 2.63% of GDP

If profit is shifted to a tax haven in the form of interest, this would show up as a high

balance of intra-group interest received minus paid, both in absolute terms and as a share

of GDP. The data are based on IMF CDIS information, using partner data from 80

countries to derive loan assets and from 58 countries to derive loan liabilities (these are all

the reporting countries for each item).

Using this data, Oxfam identified:

Cayman Islands

Bermuda

Luxembourg

Jersey

Curaçao

Switzerland

Netherlands

Malta

73.0% of GDP

40% of GDP

25% of GDP

7% of GDP

4.3% of GDP

1.8% of GDP

1.7% of GDP

1.2% of GDP

$1,830m

$ 2,210m

$14,419m

$ 354m

$136m

$12,375m

$ 12,784m

$ 120m

•

Level of interest paid and received superior to 2,5% of GDP

Using this data, Oxfam identified (conduit jurisdiction assessment):

Paid

Received

Luxembourg 60.47% of GDP

Netherlands 4.53% of GDP

Luxembourg 83.64% of GDP

Netherlands 6.89% of GDP

3 Weight of dividends (limited access to information due to the lack of reporting

from many jurisdictions)

•

Level of dividends paid and received in excess of 5% GDP (conduit jurisdiction

assessment):

Using this data, Oxfam identified:

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Paid

Luxembourg 87.28% of GDP

Mauritius 34.41% of GDP

China, Hong Kong SAR 16.03% of

GDP

Netherlands 14.31% of GDP

Switzerland 6.15% of GDP

4 Foreign direct investment stock levels

•

Received

Luxembourg 110.02% of GDP

Mauritius 31.69% of GDP

Netherlands 20.29% of GDP

China, Hong Kong SAR 15.42% of

GDP

Switzerland 8.27% of GDP

FDI inward stock minus FDI outward stock in excess of 250% GDP

Very

high inward FDI relative to a country’s economy is usually related to offshore

structures. Oxfam analysed the balance of inward FDI stock minus outward FDI stock.

Using this data, Oxfam identified:

Cayman Islands 3.913% of GDP

Malta 1.038% of GDP

•

Level of FDI inward stock and outward stock in excess of 250% of GDP (conduit

jurisdiction assessment)

Using this data, Oxfam identified:

Inward:

British Virgin Islands 66.950% of GDP

Cayman Islands 9.311% of GDP

Malta 1.687% of GDP

China, Hong Kong SAR 496% of GDP

Luxembourg 421% of GDP

Ireland 286% of GDP

5 Risks of transfer pricing mismatches

•

Total goods exports to the world in excess of 100% GDP

Outward:

British Virgin Islands 91.570% of GDP

Cayman Islands 5.400% of GDP

Malta 650% of GDP

China, Hong Kong SAR 477% of GDP

Luxembourg 395% of GDP

Ireland 283% of GDP

Very high exports compared with GDP can indicate that excessive trade flows are being

routed through a jurisdiction.

Using this data, Oxfam identified:

China, Hong Kong SAR 150% of GDP

Singapore 117% of GDP

As a conclusion, Oxfam identified the 14 following jurisdictions as failing the EU criterion on

Fair Taxation [countries solely identified as conduit tax havens are marked with*]:

Bahamas

Bermuda

British Virgin Islands*

Cayman Islands

China, Hong Kong SAR

Curaçao

Ireland*

Jersey

Luxembourg

Malta

Mauritius*

Netherlands

Singapore

Switzerland

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Scoring on criteria 3: Implementation of anti-BEPS measures

Box 3: EU criteria on implementation of anti-BEPS measures

3.1. Initial criterion that a jurisdiction should fulfil in order to be considered compliant

as regards the implementation of anti-BEPS measures: the jurisdiction, should

commit, by the end of 2017, to the agreed OECD anti-BEPS minimum standards and

their consistent implementation.

3.2. Future criterion that a jurisdiction should fulfil in order to be considered compliant

as regards the implementation of anti-BEPS measures (to be applied once the

reviews by the Inclusive Framework of the agreed minimum standards are

completed): the jurisdiction should receive a positive assessment for the effective

implementation of the agreed OECD anti-BEPS minimum standards.

Source: Council of the EU (2016).

Criteria and process leading to the establishment of the EU list of non-

cooperative jurisdictions for tax purposes

- 14166/16, http://data.consilium.europa.eu/doc/document/ST-

14166-2016-INIT/en/pdf

In line with the EU’s criteria on implementation of anti-BEPS

measures (see Box 3) Oxfam

assessed countries on:

•

Being a member of the inclusive framework;

Any other public trace of BEPS minimum standards commitments.

After applying this, we found 25 jurisdictions to be failing on EU anti-BEPS criteria. These

countries are:

Albania

Anguilla

Antigua and Barbuda

Aruba

Bahamas

Bahrain

Bosnia and Herzegovina

Cook Islands

Faroe Islands

Final list including all countries: Oxfam identified 35 third jurisdictions and 4 EU countries.

Former Yugoslav Republic of Macedonia

Gibraltar

Greenland

Guam

Marshall Islands

Montenegro

Nauru

New Caledonia

Niue

Palau

Serbia

Taiwan

Trinidad and Tobago

United Arab Emirates

US Virgin Islands

Vanuatu

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TABLE 1: The countries and territories which should at the very minimum appear

on the EU blacklist, and reasons

Jurisdiction

Fails

criterion 1:

Tax

transparency

Fails

criterion 2:

Fair taxation

Fails criterion 3:

Implementation

of anti-BEPS

measures

Albania

Anguilla

Antigua and Barbuda

Aruba

Bahamas

Bahrain

Bermuda

Bosnia and Herzegovina

British Virgin Islands*

Cook Islands

Cayman Islands

Curaçao

Faroe Islands

Former Yugoslav Republic of Macedonia

Gibraltar

Greenland

Guam

Hong Kong

Jersey

Marshall Islands

Mauritius*

Montenegro

Nauru

New Caledonia

Niue

Oman

Palau

Serbia

Singapore

Switzerland

Taiwan

Trinidad and Tobago

United Arab Emirates

US Virgin Islands

Vanuatu

* Indicates that the jurisdiction has been identified as a conduit tax haven.

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TABLE 2: The four EU countries that Oxfam identified

Jurisdiction

Fails criterion 1:

Tax transparency

Fails criterion 2:

Fair taxation

Fails criterion 3:

Implementation of

anti-BEPS measures

Ireland*

Luxembourg

Malta

Netherlands

NOTES

Euractiv (2017).

Member states’

broad definition of tax havens raises concerns,

https://www.euractiv.com/section/economy-jobs/news/member-states-broad-definition-of-tax-

havens-raises-concerns/

Esmé Berkhout (2016).

Tax Battles: The dangerous global race to the bottom on corporate tax.

Oxfam Briefing Paper. http://oxf.am/ZuCG

World Bank, https://data.worldbank.org/income-level/low-and-middle-income

OECD (2017).

AEOI Status of Commitments,

https://www.oecd.org/tax/transparency/AEOI-

commitments.pdf

OECD.

Global Forum on Transparency and Exchange of Information for Tax Purposes.

http://www.oecd.org/tax/transparency/exchange-of-information-on-request/ratings/

OECD, http://www.oecd.org/tax/exchange-of-tax-information/Status_of_convention.pdf

All discussions regarding the economic assessment of the 92 jurisdictions are taking place in a

secret working group called the Code of Conduct group on Business Taxation.

European Commission (2016), First step towards a new EU list of third country jurisdictions:

Scoreboard

OECD (2015) Countering Harmful Tax Practices More Effectively, Taking into Account

Transparency and Substance, Action 5 - 2015 Final Report; OECD (2017) Inclusive Framework

on BEPS Progress report July 2016-June 2017; OECD (2017) Harmful Tax Practices - 2017

Progress Report on Preferential Regimes

10 Information gathered on Big 4 information websites such as KPMG:

https://home.kpmg.com/xx/en/home/services/tax/tax-tools-and-resources/tax-rates-

online/corporate-tax-rates-table.html

Deloitte, https://www2.deloitte.com/content/dam/Deloitte/global/Documents/Tax/dttl-tax-corporate-

tax-rates.pdf

Or national website of the jurisdiction.

11 There is a debate on whether or not to consider dividends as passive income.

12 Eurostat, http://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=bop_its6_det&lang=en

13 IMF data: http://data.imf.org/regular.aspx?key=60979251

14 IMF data: http://cdis.imf.org

15 IMF data: http://data.imf.org/regular.aspx?key=60979251

16 Ibid

17 UN Stats, http://unctadstat.unctad.org/wds/ReportFolders/reportFolders.aspx

18 UN Stats, http://unctadstat.unctad.org/wds/ReportFolders/reportFolders.aspx

19 UN Stats

http://unstats.un.org/unsd/trade/imts/UNSD%20Annual%20Totals%20Table%20(ATT)%202000-

2015%20(as%20of%2017%20Jan%202017).xlsx

20 OECD (2017).

Members of the Inclusive Framework on BEPS.

https://www.oecd.org/ctp/beps/inclusive-framework-on-beps-composition.pdf

21 Various sources in the media.

Assessing Jurisdictions Against EU Listing Criteria: Oxfam methodology