從泄露的賬戶數(shù)據(jù)中可以看出精英如何使用離岸銀行

1、What lies beneath: evidence from leaked account data on how elites use offshore bankingMatthew Collin Brookings Institution May 5, 2021AbstractThis paper uses account data leaked from an Isle of Man bank to investigate the character- istics of individuals and firms that store their money in tax have

2、ns. Using internal documents that assign the ultimate ownership of companies and trusts that held deposits at the bank, I establish three things: first, most customers are from rich countries and are likely to be from the upper end of the income and wealth distributions of those countries. Second, I

3、 show that a non-negligible amount of offshore wealth is connected to a small number of political elites (so called politically-exposed persons). On average, these accounts have substantially higher bal- ances and are more likely to receive payments from other tax havens, which is consistent with po

4、litically-exposed persons having access to more resources than the average offshore client while also desiring to obscure that ownership. Finally, I show that a substantial proportion of bank deposits are obscured from publicly-available statistics published by the Bank of Inter- national Settlement

5、s which are commonly used to measure offshore wealth. When I correctly assign deposits to their ultimate beneficial owner, offshore bank deposits owned by residents of tax havens drops by up to 32% and deposits held by residents of non-havens doubles. I conclude with recommendations on how reporting

6、 requirements need to change to improve the ability of regulators and the research community to detect and counter illicit finance.JEL classiftcation: D73, E21, H26, H87Email: HYPERLINK mailto:mcollin mcollin. I would like to thank Sydney Gordon, Niels Johannesen, Andreas Kern, Homi Kharas,Dominika

7、Langenmayr, Jakob Miethe, Bob Rijkers, Jason Sharman, Justin Sandefur, Jared Schott, Barbara Stage, David Szakonyi, Gerhard Toews, Emile Van Der Does De Willebois and Pierre-Louis Vezina for their helpful comments and suggestions, Arun Advani for providing the UK wealth distribution data, Friedrich

8、Lindenberg at the OCCRP and both Louis Goddard and Sam Leon at Global Witness for useful conversations about the data. All errors are my own. The results in the paper are estimates using data that has been made available through the leak, but they should not be viewed as definitive statements of any

9、 underlying financial accounts or activity. The mention of any individual, company, organization, or other entity in this paper does not imply the violation of any law on their part and should not be construed as such. This publication was made possible by the David M. Rubenstein fellowship at the B

10、rookings Institution. Brookings recognizes that the value it provides is in its absolute commitment to quality, independence, and impact. Activities supported by its donors reflect this commitment and the analysis and recommendations are not determined or influenced by any donation.The Brookings Ins

11、titution is a nonprofit organization devoted to independent research and policy solutions. Its missionis to conduct high-quality, independent research and, based on that research, to provide innovative, practical recommendations for policymakers and the public. The conclusions and recommendations of

12、 any Brookings publication are solely those of its author(s), and do not reflect the views of the Institution, its management, or its other scholars.IntroductionWealth can travel around the world with relative ease, but a governments ability to keep track of it is largely confined to its own borders

13、. It is this information asymmetry that gives rise to a host of problems, the first of which is the ability of people to evade taxation by parking their wealth in other jurisdictions, away from the prying eyes of the tax authority. Recent evidence suggests that random audits of wealthy individuals r

14、outinely underestimate tax evasion by those who keep some of their money offshore ( HYPERLINK l _bookmark26 Alstadster, Johannesen, HYPERLINK l _bookmark26 and Zucman 2019a; HYPERLINK l _bookmark49 Guyton, Langetieg, Reck, Risch, and Zucman 2021). Not only is the amount of offshore wealth that goes

15、undeclared to tax authorities likely to be substantial ( HYPERLINK l _bookmark25 Alstadster, Johannesen, and Zucman 2018), the fact that the rich are more likely to engage in this behavior ( HYPERLINK l _bookmark26 Alstadster, Johannesen, and Zucman 2019a; HYPERLINK l _bookmark63 Londono-Velez and H

16、YPERLINK l _bookmark63 Avila-Mahecha 2021; HYPERLINK l _bookmark61 Lejour, Rabate, vant Riet, et al. 2020) suggests that efforts to curb inequality through taxation be ineffective until authorities improve their ability to observe their taxpayers worldwide income and wealth.A second, interrelated, p

17、roblem is the fact that political elites and their associates who wish to abuse their public office or political power for private gain can pull this off more successfully when the gains are accrued offshore. It is easier to deny you have amassed a lot of wealth while in office when your government

18、lacks the ability to observe what you own overseas and there is no local, conspicuous pot of money that someone can point to. This behavior is rife enough to be observable in international statistics: when high-corruption countries receive an influx of oil-revenue or foreign aid, offshore wealth own

19、ed by its resi- dents surges ( HYPERLINK l _bookmark28 Andersen, Johannesen, Lassen, and Paltseva 2017; HYPERLINK l _bookmark54 Johannesen, Andersen, and HYPERLINK l _bookmark54 Rijkers 2020).The presence of offshore financial centers (OFCs) - colloquially known as tax havens - complicates the infor

20、mation asymmetry problem even more. Historically, many havens have offered both a low level of taxation and a high degree of financial secrecy: laws and policies that make very difficult for anyone, governments included, to understand who owns what. Ironically, the most concrete evidence that many O

21、FCs have acted as havens for tax evaders has been generated by their gradual embrace of transparency: several studies have shown that foreign deposits held in these jurisdictions decline sharply after they sign agreements to share information on these deposits with foreign tax authorities ( HYPERLIN

22、K l _bookmark56 Johannesen and Zucman HYPERLINK l _bookmark56 2014; HYPERLINK l _bookmark33 Beer, Coelho, and Leduc 2019; HYPERLINK l _bookmark64 Menkhoff and Miethe 2019; HYPERLINK l _bookmark72 OReilly, Ramirez, and HYPERLINK l _bookmark72 Stemmer 2019; HYPERLINK l _bookmark36 Casi, Spengel, and S

23、tage 2020). Today, traditional small-island havens have been joined by some of the worlds biggest economies - such as the US - as the destination for untaxed and corrupt wealth ( HYPERLINK l _bookmark80 Van der Does de Willebois et al. 2011; HYPERLINK l _bookmark47 Findley et al. 2014; HYPERLINK l _

24、bookmark36 Casi et al. 2020). In both old and new destinations of illicit finance, multiple, overlapping legal structures that obscure the true owner of wealth (such as shell companies or trusts) are a common means to maintaining secrecy.Researchers face the same information asymmetry problem that g

25、overnments do: our attempts to understand how people evade tax and how they engage with the offshore financial center are hampered by the fact that most of this behavior is hidden by its very nature. Most research thus relies on either publicly-available, aggregate statistics or confidential data fr

26、om tax authorities to understand how the offshore world functions and how taxpayers interact with it. These approaches are highly useful, but they are also incomplete: trying to understand what is happening to offshore wealth via these methods is analogous to sitting on a boat and inferring what is

27、happening underwater by observing how the waves change (or sporadically interviewing people who swim to the surface).Occasionally though we get a peek beneath the waves: over the past decade there has been a surge in high-profile leaks of data from banks based in tax havens and from the service prov

28、iders that help people and companies organize their affairs offshore. The most high profile of these was the leak of customer information from the Panamanian law firm Mossack Fonseca (the Panama Papers). These offer an unprecedented opportunity to better understand how people hide their money in tax

29、 havens. Yet, possibly because they are often limited in both their scope and in what they can measure, few studies have relied on aggregated data from these leaks to directly understand the impact of policy (see HYPERLINK l _bookmark35 Caruana- HYPERLINK l _bookmark35 Galizia and Caruana-Galizia (2

30、016) and HYPERLINK l _bookmark70 Omartian (2017) for examples of those that have). HYPERLINK l _bookmark0 1 This paper takes a long dive beneath the surface: it uses data leaked from a bank incorporated in the Isle of Man - one that was a popular destination for high net worth individuals - to bette

31、r understand who holds their money in offshore financial centers and how well our methods of measuring it may be working. The advantage of using leaked data is that, in many instances, it allows me to peer through the opaque legal structures that dominate the financial industry to establish the owne

32、rs of a large share of accounts, asrecorded by the bank.In doing so, I establish three descriptive results. The first is that the clients of offshore banks are likely to be rich, both in that they reside in rich countries and that they are likely to be from the upper-end of the income and wealth dis

33、tribution in those same countries.1In addition to these, HYPERLINK l _bookmark62 Londono-Velez and Avila-Mahecha (2020) , HYPERLINK l _bookmark63 Londono-Velez and Avila-Mahecha HYPERLINK l _bookmark63 (2021) and ( HYPERLINK l _bookmark26 Alstadster, Johannesen, and Zucman 2019a) match names from th

34、ese leaks to administrative data, but most of their analyses do not exploit the structure of the Panama Papers data in any substantial way (although HYPERLINK l _bookmark62 Londono-Velez and Avila-Mahecha (2020) does use information on the date an offshore company was incorporated to study the effec

35、ts of moving wealth offshore on what gets reported to the tax authority back home).While this is not a novel, earth-shattering finding, it reinforces growing evidence coming out of a number of countries that offshore banking is a luxury service and thus, to the extent that it is being used to evade

36、or avoid tax, it has major implications for the ability of societies to fight inequality and raise revenue through progressive taxation.The second is that a significant share of offshore deposits are controlled by clients who are connected to politically-influential people, such as current and forme

37、r politicians, their family and friends. A number of these are from countries that score poorly on popular measures of corruption risk. These politically-exposed clients not only hold greater amounts of wealth than the average offshore client, but they are also more likely to have an address in a ta

38、x haven and are more likely to receive money into their accounts from accounts in other tax havens, all signs that significantly raise the risk that these clients have access to higher levels of wealth and are more willing to engage in activity that obscures their ownership of it. This is despite th

39、e fact that these clients were all successfully identified and were monitored by the bank in question.The third result is that the legal arrangements that most customers of offshore banks used to organize their affairs, shell companies and trusts, interfere with the ability of popular measures of cr

40、oss-border liabilities to measure offshore wealth. A growing amount of work on the level and determinants of offshore deposits relies on data from the Bank of International Settlementss Locational Banking Statistics (BIS LBS), which assigns ownership of deposits based on the immediate counterparty.

41、In practice, this means that deposits owned by shell companies based in tax havens will be assigned to those havens, rather than to the location of the ultimate owner, a limitation widely recognized (and occasionally exploited) by researchers working in this space ( HYPERLINK l _bookmark56 Johannese

42、n and Zucman 2014; HYPERLINK l _bookmark36 Casi, Spengel, and Stage 2020). Using data on the ultimate owner of banks deposits from the leak combined with reports prepared for the LBS, I show that over half of deposits are controlled by entities based in tax havens and that many of these are incorrec

43、tly assigned as being haven deposits, despite being controlled by residents of non-haven jurisdictions. This not only implies that our measures of non-bank cross-border liabilities may be distorted by the presence of tax havens, it might also bias studies on the impact of transparency initiatives in

44、 ways that are hard to bound.The paper is organized as follows: in Section HYPERLINK l _bookmark1 2, I discuss the Isle of Mans role in the off- shore financial sector, the data breach that I rely on for this paper, and aggregate descriptive statistics on both the clients and trends in deposits. In

45、Section HYPERLINK l _bookmark5 3 I discuss the distribution of clients across countries and their levels of wealth. Section HYPERLINK l _bookmark11 4 presents the results on accounts maintained by clients with connections to politically-influential people. Section HYPERLINK l _bookmark16 5 discusses

46、 the results on the measurement of offshore wealth. I discuss potential policy solutions and conclude with Section HYPERLINK l _bookmark22 6.Background and dataThe Isle of ManThe Isle of Man is one of three British Crown dependencies, self-governing jurisdictions situ- ated around the British Isles.

47、 It has been classified as an “offshore financial centre” (OFC) by the International Monetary Fund (IMF), a designation for jurisdictions that have a banking sector largely oriented towards non-residents, very high levels of external assets and liabilities relative to the size of the economy, and se

48、rvices that make them particularly attractive for foreign wealth and profits, such as low levels of taxation, regulation or transparency. HYPERLINK l _bookmark0 2 With the exception of banking and retail businesses based on the island, which are taxed at 10%, most corporate income goes untaxed. HYPE

49、RLINK l _bookmark0 3 Top marginal income tax rates for residents are 20%. The jurisdiction is considered by many to be a tax haven. Two decades ago the OECD listed it as such in an effort to get it to commit to exchange of information for tax purposes ( HYPERLINK l _bookmark69 OECD 2000). In the fir

50、st publication of its most recent grey and black lists, the European Union flagged the Isle of Man for “existence of tax regimes that facilitate offshore structures which attract profits without real economic activity.” It ranks 20 out of 70 in the latest edition of the Tax Justice Networks Corporat

51、e Tax Haven Index ( HYPERLINK l _bookmark31 Ates et al. 2020) and 43 out of 133 in its Financial Secrecy Index ( HYPERLINK l _bookmark77 Tax Justice Network 2020), two measures aimed at understanding how popular a jurisdiction is for hiding ones wealth or for profit shifting. Like many offshore fina

52、ncial centers, the Isle of Man has adopted a number of policies over the past decade aimed at curbing these behaviors, including many of the minimum stan- dards proposed by the OECD as part of its Base Erosion and Profit Shifting (BEPS) project as well as various forms of automatic-exchange-of infor

53、mation for tax purposes (AEOI). For the former, it is unclear at this stage whether this had made a major dent in profit shifting: HYPERLINK l _bookmark79 Trslv, Wier, and Zucman (2020) calculate that in 2015 nearly 80% of the $3.1 billion in corporate profits that were booked on the Isle were artif

54、icially-shifted profits. The Isle also continues to be relatively attractive to foreign banks: as of December, 2020, over 60% of the number of active banks in the jurisdiction are foreign banks with no local incorpora- tion. Using data from country-by-country reporting (CbCr) reports from EU banks,

55、HYPERLINK l _bookmark41 Delatte, HYPERLINK l _bookmark41 Capelle-blancard, and Bouvatier (2021) show that tax havens accommodate three times as many foreign-owned banks as other jurisdictions.Despite this, there are signs that offshore banking is on the wane, as the past decade has seen a steady dec

56、line in banking deposits controlled by foreigners. Figure HYPERLINK l _bookmark2 1(a) displays2The IMF has since retired the term OFC, after integrating its OFC assessment program into its Financial Sector Assessment Program (FSAP).3Businesses are only taxed if they make more than half a million GBP

57、 in profit in a given year.the sum of all non-bank cross-border deposits as measured by the BISs Locational Banking Statistics. HYPERLINK l _bookmark0 4. Foreign-owned deposits have been declining steadily since the financial crisis, a trend that is likely attributable to a number of transparency re

58、gimes adopted by the Isle of Man during this period. This includes the signing of a number of tax exchange-of-information on request agreements and the arrival of both the USs Foreign Account Tax Compliance Act (FATCA) and the OECDs Common Reporting Standard (CRS) for the automatic exchange- of-info

59、rmation, all policies aimed at allowing foreign tax authority to better observe wealth being held on the Isle. Irrespective of the acronym, each of these initiatives has been shown to have a causal impact on the amount of offshore deposits controlled by foreigners ( HYPERLINK l _bookmark56 Johannese

60、n HYPERLINK l _bookmark56 and Zucman 2014; HYPERLINK l _bookmark33 Beer et al. 2019; HYPERLINK l _bookmark64 Menkhoff and Miethe 2019; HYPERLINK l _bookmark72 OReilly et al. 2019; HYPERLINK l _bookmark36 Casi HYPERLINK l _bookmark36 et al. 2020). The BIS also collects information on locally held non