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A large puzzle underlies the recent G20 and OECD Base Erosion and Profit Shifting (BEPS) project. If the scope of BEPS is as broad as the reports suggest, why are corporate tax revenues in the OECD so robust? The final OECD report on BEPS action 11 suggest that BEPS activities result in between $100 and $240 billion in annual lost revenue fromcorporate income taxes (CIT) ona global basis. The wide spread between these two numbers indicates the significantuncertainty involved. But even the higher number represents a relatively small portion of total global CIT revenues, since it is only about half of the annual CIT revenue of the US alone. Moreover, overall OECD revenue data do not indicate that BEPS has had a significant impact on CIT revenue, since those have held steady at 8-10% of total revenue since the 1980s (i.e., before BEPS became a significant issue).1 These data are surprising in light of what we know about the extent of tax avoidance by U.S. multinationals. Currently, U.S.-based multinationals have accumulatedover $2.5 trillion in low tax jurisdictions offshore, and the U.S. tax on that income (most of which has been accumulated since 2005, when a one year amnesty allowed previous profits to be repatriated) is about $800 billion, which is also the ten year estimate of the cost of deferral to theU.S. Treasury.2 These data suggest that if theOECD esti-

Three steps forward, one step back? Reflections on “google taxes” and the destination-based corporate tax