As globalization accelerates, the number of multinational enterprises (MNEs) continues to grow, and these firms increasingly exploit differences in international tax systems to develop sophisticated tax avoidance structures. In particular, companies t...
As globalization accelerates, the number of multinational enterprises (MNEs) continues to grow, and these firms increasingly exploit differences in international tax systems to develop sophisticated tax avoidance structures. In particular, companies that establish subsidiaries in tax havens often engage in seemingly legitimate cross-border transactions while, in reality, employing aggressive tax avoidance strategies such as non-reporting of income and assets to domestic authorities. Such practices hinder tax administrations in effectively exercising their taxing rights.
This study empirically examines the policy effectiveness of three major anti–offshore tax evasion measures introduced to regulate tax avoidance by MNEs and to ensure tax compliance: the Offshore Financial Account Reporting System (OFARS), the Multilateral Competent Authority Agreement (MCAA) for automatic exchange of financial information, and the Country-by-Country Reporting (CbCR) system. The sample comprises Korean listed firms with subsidiaries located in tax havens, covering the period from 2007 to 2019. Firm-level financial data were obtained from NICE VALUE SEARCH and TS2000, and after excluding firms with insufficient information or extreme outliers, the final sample consists of 3,458 firm-year observations.
The empirical results are as follows. First, among the proxies for international diversification, the proportion of foreign sales and the presence of tax haven subsidiaries are significantly associated with corporate tax avoidance, whereas the proportion of foreign assets is not. Second, anti–offshore tax evasion regulations are effective in curbing tax avoidance by multinational firms. Third, after the implementation of these regulations, multinational firms with tax haven subsidiaries exhibit a reduction in tax avoidance behaviors.
The findings of this study reaffirm the importance of preventing offshore tax evasion through international transactions and the use of tax haven entities, and highlight the critical role of anti–offshore tax evasion measures in securing stable offshore tax bases. Given that these measures demonstrably increase the corporate tax burden on multinational firms, several policy recommendations are suggested to further enhance their effectiveness. First, due to the covert nature of offshore tax evasion and the difficulty of accessing relevant information, securing high-quality non-public information is crucial. Dedicated organizational structures and systems aligned with OSINT, TECHINT, and HUMINT frameworks should be strengthened to ensure continuous acquisition of advanced intelligence. Second, multilateral and bilateral international cooperation must be reinforced. Active participation in global cooperative frameworks and the expansion of human and material networks are essential, along with the establishment of a fast-track bilateral information-sharing program to improve the speed and accuracy of information exchange. Third, an AI-based analytical system should be expanded to enhance and refine the utilization of diverse offshore tax-related information. An advanced AI-driven framework should be established to creatively learn from a wide spectrum of data—including accounting records, tax filings, international cooperation data, tax evasion reports, informal intelligence, academic research, tax audit cases, judicial precedents and rulings, statutory provisions, administrative guidelines, and taxation cases from foreign jurisdictions—and to identify potential new offshore tax bases through its analytical processes.
Despite these contributions, the study has several limitations. First, the adoption of IFRS in 2011 may have created inconsistencies between pre- and post-2011 financial reporting standards, potentially influencing the empirical findings regarding the effects of OFARS. Second, by restricting the sample to firms continuously listed from 2007 to 2019, the study faces limitations in generalizability, as many firms were excluded and non-listed but externally audited firms were not examined. Third, although the study evaluates the pre- and post-implementation effects of OFARS, MCAA, and CbCR individually, it does not compare their relative effectiveness in deterring offshore tax evasion. Future research should address these limitations and further investigate policy measures to counteract offshore tax evasion through international diversification and the use of tax haven subsidiaries by multinational enterprises.