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Dear Sir and Madam,
 
UNCTAD's Division on Investment and Enterprise is today circulating a 
working paper for broad-based feedback to support ongoing work on the 
theme of FDI, Tax and Development.
 
The paper aims to provide a baseline for the ongoing debate in the 
international community on tax avoidance, with estimates for the 
contribution of multinational enterprises (MNEs) to government revenues in 
developing countries, and estimates for the impact of base erosion and 
profit shifting (BEPS):
 
- The total MNE contribution to developing country government revenues is 
estimated at some US$730 billion annually. This represents on average just 
over 10% of total government revenues.
 
- Tax-avoidance revenue losses associated with offshore investment links 
are calculated at around US$100 billion. This is around one-third of the 
corporate income tax part of the larger overall fiscal contribution of 
MNEs.
 
- A significant share of cross-border corporate investment transits 
through offshore investment hubs. An additional 10% of investment routed 
through offshore hubs is associated with a 1 percentage point lower 
reported (taxable) rate of return.
 
The paper provides an investment perspective on international tax 
avoidance, leading to new insights on the links between investment and tax 
policies. The study proposes a set of draft guiding principles for 
Coherent International Tax and Investment Policies as a basis for public 
debate.
 
Finally, through its Technical Annexes, the paper responds to demand in 
the international community for new ideas and approaches to examining the 
fiscal impact of MNEs – including an explicit call in the G20 BEPS Action 
Plan (Action Point 11). Methodological innovations proposed include the 
Offshore Investment Matrix, the Contribution and FDI-Income Methods for 
the calculation of MNE fiscal contributions, and the FDI-Income-Based 
Revenue Loss Analysis.
 
With its work on FDI, Tax and Development, initiated in response to demand 
from Member States, UNCTAD's Division on Investment and Enterprise aims to 
complement ongoing work of the UN Committee of Experts on International 
Cooperation in Tax Matters and the work of the OECD on BEPS, by providing 
an investment and development perspective.
 
We request feedback on our working paper, and in particular on the 
proposed guidelines for Coherent International Tax and Investment 
Policies, through our Investment Policy Hub (
http://investmentpolicyhub.unctad.org/).
 
Best regards,
 
James Zhan
Director
Investment & Enterprise
United Nations Conference on Trade & Development