Tag: corporation tax

Rishi Sunak delivered his 2021 UK Budget on 3 March. It illustrates the delicate balancing act that governments in many countries face as the effects of the coronavirus pandemic persist and public-sector debt soars. He announced that he would continue supporting the economy through various forms of government expenditure and tax relief, but also announced tax rises over the medium term to begin addressing the massively increased public-sector debt.

Key measures of support for people and businesses include:

  • An extension of the furlough scheme until the end of September, with employees continuing to be paid 80% of their wages for hours they cannot work, but with employers having to contribute 10% in July and 20% in August and September.
  • Support for the self-employed also extended until September, with the scheme being widened to make 600 000 more self-employed people eligible.
  • The temporary £20 increase to Universal Credit, introduced in April last year and due to end on 31 March this year, to be extended to the end of September.
  • Stamp duty holiday on house purchases in England and Northern Ireland, under which there is no tax liability on sales of less than £500 000, extended from the end of March to the end of June.
  • An additional £1.65bn to support the UK’s vaccination rollout.
  • VAT rate for hospitality firms to be maintained at the reduced 5% rate until the end of September and then raised to 12.5% (rather than 20%) for a further six months.
  • A range of grants for the arts, sport, shops , other businesses and apprenticeships.
  • Business rates holiday for hospitality firms in England extended from the end of March to the end of June and then with a discount of 66% until April 2022.
  • 130% of investment costs can be offset against tax – a new tax ‘super-deduction’.
  • No tax rises on alcohol, tobacco or fuel.
  • New UK Infrastructure Bank to be set up in Leeds with £12bn in capital to support £40bn worth of public and private projects.
  • Increased grants for devolved nations and grants for 45 English towns.

It has surprised many commentators that there was no announcement of greater investment in the NHS or more money for social care beyond the £3bn for the NHS and £1bn for social care announced in the November Spending Review. The NHS England budget will fall from £148bn in 2020/21 to £139bn in 2021/22.

Effects on borrowing and GDP


The net effect of these measures for the two financial years 2020 to 2022 is forecast by the Treasury to be an additional £37.5bn of government expenditure and a £27.3bn reduction in tax revenue (see Table 2.1 in Budget 2021). This takes the total support since the start of the pandemic to £352bn across the two years.

According to the OBR, this will result in public-sector borrowing being 16.9% of GDP in 2020/21 (the highest since the Second World War) and 10.3% of GDP in 2021/22. Public-sector debt will be 107.4% of GDP in 2021/22, rising to 109.7% in 2023/24 and then falling to 103.8% in 2025/26.

Faced with this big increase in borrowing, the Chancellor also announced some measures to raise tax revenue beginning in two years’ time when, hopefully, the economy will have grown. Indeed, the OBR forecasts that GDP will grow by 4.0% in 2021 and 7.3% in 2022, with the growth rate then settling at around 1.7% from 2023 onwards. He announced that:

  • Corporation tax on company profits over £250 000 will rise from 19% to 25% in April 2023. Rates for profits under £50 000 will remain at the current rate of 19%, with the rate rising in stages as profits rise above £50 000.
  • Personal income tax thresholds will be frozen from 2022/23 to 2025/26 at £12 570 for the basic 20% marginal rate and at £50 270 for the 40% marginal rate. This will increase the average tax rate as people’s nominal incomes rise.

The policy of a fiscal boost now and a fiscal tightening later might pose political difficulties for the government as this does not fit with the electoral cycle. Normally, politicians like to pursue tighter policies in the early years of the government only to loosen policy with various giveaways as the next election approaches. With Rishi Sunak’s policies, the opposite is the case, with fiscal policy being tightened as the 2024 election approaches.

Another issue is the high degree of uncertainty in the forecasts on which he is basing his policies. If there is another wave of the coronavirus with a new strain resistant to the vaccines or if the scarring effects of the lockdowns are greater, then growth could stall. Or if inflation begins to rise and the Bank of England feels it must raise interest rates, then this would suppress growth. With lower growth, the public-sector deficit would be higher and the government would be faced with the dilemma of whether it should raise taxes, cut government expenditure or accept higher borrowing.

What is more, there are likely to be huge pressures on the government to increase public spending, not cut it by £4bn per year in the medium term as he plans. As Paul Johnson of the IFS states:

In reality, there will be pressures from all sorts of directions. The NHS is perhaps the most obvious. Further top-ups seem near-inevitable. Catching up on lost learning in schools, dealing with the backlog in our courts system, supporting public transport providers, and fixing our system for social care funding would all require additional spending. The Chancellor’s medium-term spending plans simply look implausibly low.

Articles and Briefings

Official documents and data

Questions

  1. Assess the wisdom of the timing of the changes in tax and government expenditure announced in the Budget.
  2. Universal credit was increased by £20 per week in April 2020 and is now due to fall back to its previous level in October 2021. Have the needs of people on Universal Credit increased during the pandemic and, if so, are they likely to return to their previous level in October?
  3. In the past, the government argued that reductions in the rate of corporation tax would increase tax revenue. The Chancellor now argues that increasing it from 19% to 25% will increase tax revenue. Examine the justification for this increase and the significance of relative profit tax rates between countries.
  4. Investigate the effects on the public finances of the pandemic and government fiscal policy in two other countries. How do the effects compare with those in the UK?
  5. The Joseph Rowntree Foundation looks at poverty in the UK and policies to tackle it. It set five tests for the Budget. Examine its Budget Analysis and consider whether these tests have been met.

The latest edition of the IMF’s Fiscal Monitor, ‘Tackling Inequality’ challenges conventional wisdom that policies to reduce inequality will also reduce economic growth.

While some inequality is inevitable in a market-based economic system, excessive inequality can erode social cohesion, lead to political polarization, and ultimately lower economic growth.

The IMF looks at three possible policy alternatives to reduce inequality without damaging economic growth

The first is a rise in personal income tax rates for top earners. Since top rates have been cut in most countries, with the OECD average falling from 62% to 35% over the past 30 years, the IMF maintains that there is considerable scope of raising top rates, with the optimum being around 44%. Evidence suggests that income tax elasticity is low at most countries’ current top rates, meaning that a rise in top income tax rates would only have a small disincentive effect on earnings.

An increased progressiveness of income tax should be backed by sufficient taxes on capital to prevent income being reclassified as capital. Different types of wealth tax, such as inheritance tax, could also be considered. Countries should also reduce the opportunities for tax evasion.

The second policy alternative is a universal basic income for all people. This could be achieved by various means, such as tax credits, child benefits and other cash benefits, or minimum wages plus benefits for the unemployed or non-employed.

The third is better access to health and education, both for their direct effect on reducing inequality and for improving productivity and hence people’s earning potential.

In all three cases, fiscal policy can help through a combination of taxes, benefits and public expenditure on social infrastructure and human capital.

But a major problem with using increased tax rates is international competition, especially with corporation tax rates. Countries are keen to attract international investment by having corporation tax rates lower than their rivals. But, of course, countries cannot all have a lower rate than each other. The attempt to do so simply leads to a general lowering of corporation tax rates (see chart in The Economist article) – to a race to the bottom. The Nash equilibrium rate of such a game is zero!

Videos

Raising Taxes on the Rich Won’t Necessarily Curb Growth, IMF Says Bloomberg, Ben Holland and Andrew Mayeda (11/10/17)
The Fiscal Monitor, Introduction IMF (October 2017)
Transcript of the Press Conference on the Release of the October 2017 Fiscal Monitor IMF (12/10/17)

Articles

Higher taxes can lower inequality without denting economic growth The Economist, Buttonwood (19/10/17)
Trump says the US has the highest corporate tax rate in the world. He’s wrong. Vox, Zeeshan Aleem (31/8/17)
Reducing inequality need not hurt growth Livemint, Ajit Ranade (18/10/17)
IMF: higher taxes for rich will cut inequality without hitting growth The Guardian, Larry Elliott and Heather Stewart (12/10/17)

IMF Fiscal Monitor

IMF Fiscal Monitor: Tackling Inequality – Landing Page IMF (October 2017)
Opening Remarks of Vitor Gaspar, Director of the Fiscal Affairs Department at a Press Conference Presenting the Fall 2017 Fiscal Monitor: Tackling Inequality IMF (11/10/17)
Fiscal Monitor, Tackling Inequality – Full Text IMF (October 2017)

Questions

  1. Referring to the October 2017 Fiscal Monitor, linked above, what arguments does the IMF use for suggesting that the optimal top rate of income tax is considerably higher than the current OECD average?
  2. What are the arguments for introducing a universal basic income? Should this depend on people’s circumstances, such as the number of their children, assets, such as savings or property, and housing costs?
  3. Find out the details of the UK government’s Universal Credit. Does this classify as a universal basic income?
  4. Why may governments reject the IMF’s policy recommendations to tackle inequality?
  5. In what sense can better access to health and education be seen as a means of reducing inequality? How is inequality being defined in this case?
  6. Find out what the UK Labour Party’s policy is on rates of income tax for top earners. Is this consistent with the IMF’s policy recommendations?
  7. What does the IMF report suggest about the shape of the Laffer curve?
  8. Explain what is meant by tax elasticity and how it relates to the Laffer curve?

What have been, and will be, the monetary and fiscal responses to the Brexit vote in the referendum of 23 June 2016? This question has been addressed in speeches by Mark Carney, Governor of the Bank of England, and by George Osborne, Chancellor the Exchequer. Both recognise that the vote will cause a negative shock to the economy, which will require some stimulus to aggregate demand to avoid a recession, or at least minimise its depth.

Mark Carney stated that:

The Bank of England stands ready to provide more than £250bn of additional funds through its normal facilities. The Bank of England is also able to provide substantial liquidity in foreign currency, if required.

In the coming weeks, the Bank will assess economic conditions and will consider any additional policy responses.

This could mean that at its the next meeting, scheduled for 13/14 July, the Monetary Policy Committee will consider reducing Bank Rate from its current level of 0.5% and introducing further quantitative easing.

In a speech on 30 June, he went further:

I can assure you that in the coming months the Bank can be expected to take whatever action is needed to support growth subject to inflation being projected to return to the target over an appropriate horizon, and inflation expectations remaining well anchored.

Then in a speech on 5 July, introducing the latest Financial Stability Report, he said that the Bank of England’s Financial Policy Committee is lowering the required capital ratio of banks, thereby freeing up capital for lending to customers. The part being lowered is the ‘countercyclical capital buffer’ – the element that can be varied according to the state of the economy. Mark Carney said:

The FPC is today reducing the countercyclical capital buffer on banks’ UK exposures from 0.5% to 0% with immediate effect. This is a major change. It means that three quarters of UK banks, accounting for 90% of the stock of UK lending, will immediately have greater flexibility to supply credit to UK households and firms.

Specifically, the FPC’s action immediately reduces regulatory capital buffers by £5.7 billion and therefore raises banks’ capacity to lend to UK businesses and households by up to £150 billion. For comparison, last year with a fully functioning banking system and one of the fastest growing economies in the G7, total net lending in the UK was £60 billion.

Thus although there may be changes to interest rates and narrow money in response to economic reactions to the Brexit vote, the monetary policy framework remains unchanged. This is to achieve a target rate of CPI inflation of 2% at the 24-month time horizon.

But what of fiscal policy?

In its Charter for Budget Responsibility, updated in the Summer 2015 Budget, the government states its Fiscal Mandate:

3.2 In normal times, once a headline surplus has been achieved, the Treasury’s mandate for fiscal policy is:
   a target for a surplus on public-sector net borrowing in each subsequent year.

3.3 For the period outside normal times from 2015-16, the Treasury’s mandate for fiscal policy is:
   a target for a surplus on public-sector net borrowing by the end of 2019-20.

3.4 For this period until 2019-20, the Treasury’s mandate for fiscal policy is supplemented by:
   a target for public-sector net debt as a percentage of GDP to be falling in each year.

The target of a PSNB surplus by 2019-20 has been the cornerstone of recent fiscal policy. In order to stick to it, the Chancellor warned before the referendum that a slowdown in the economy as a result of a Brexit vote would force him to introduce an emergency Budget, which would involve cuts in government expenditure and increases in taxes.

However, since the vote he is now saying that the slowdown would force him to extend the time for reaching a surplus beyond 2019-20 to avoid dampening the economy further. But does this mean he is abandoning his fiscal target and resorting to discretionary expansionary fiscal policy?

George Osborne’s answer to this question is no. He argues that extending the deadline for a surplus is consistent with paragraph 3.5 of the Charter, which reads:

3.5 These targets apply unless and until the Office for Budget Responsibility (OBR) assess, as part of their economic and fiscal forecast, that there is a significant negative shock to the UK. A significant negative shock is defined as real GDP growth of less than 1% on a rolling 4 quarter-on-4 quarter basis. If the OBR assess that a significant negative shock:

occurred in the most recent 4 quarter period;
is occurring at the time the assessment is being made; or
will occur during the forecast period

then:

  if the normal times surplus rule in 3.2 is in force, the target for a surplus each year is suspended (regardless of future data revisions). The Treasury must set out a plan to return to surplus. This plan must include appropriate fiscal targets, which will be assessed by the OBR. The plan, including fiscal targets, must be presented by the Chancellor of the Exchequer to Parliament at or before the first financial report after the shock. The new fiscal targets must be approved by a vote in the House of Commons.
  if the shock occurs outside normal times, the Treasury will review the appropriateness of its fiscal targets for the period until the public finances return to surplus. Any changes to the targets must be approved by a vote in the House of Commons.
  once the budget is in surplus, the target set out in 3.2 above applies.

In other words, if the OBR forecasts that the Brexit vote will result in GDP growing by less than 1%, the Chancellor can delay reaching the surplus and thus not have to introduce tougher austerity measures. This, in effect, is what he is now saying and maintaining that, because of paragraph 3.5, it does not break the Fiscal Mandate. The nature of the next Budget, probably in the autumn, will depend on OBR forecasts.

A few days later, George Osborne announced that he plans to cut corporation tax from the current 20% to less than 15% – below the rate of 17% previously scheduled for 2019-20. His aim is not just to stimulate the economy, but to attract inward investment, as the rate would below that of any major economy and close the rate of 12.5% in Ireland. His hope would also be to halt the outflow of investment as companies seek to relocate in the EU.

Videos and podcasts

Statement from the Governor of the Bank of England following the EU referendum result Bank of England (24/6/16)
Uncertainty, the economy and policy – speech by Mark Carney Bank of England (30/6/16)
Introduction to Financial Stability Report, July 2016 Bank of England (5/7/16)
Osborne: Life will not be ‘economically rosy’ outside EU BBC News (28/6/16)
Osborne takes ‘realistic’ view over surplus target BBC News (1/7/16)
Why has George Osborne abandoned a key economic target? BBC News (1/7/16)

Articles

Mark Carney says Bank of England ready to inject £250bn into economy to keep UK afloat after EU referendum Independent, Zlata Rodionova (24/6/16)
Carney Signals Rate Cuts as Brexit Chaos Engulfs Political Class Bloomberg, Scott Hamilton (30/6/16)
Bank of England hints at UK interest rate cuts over coming months to ease Brexit woes International Business Times, Gaurav Sharma (30/6/16)
Carney prepares for ‘economic post-traumatic stress’ Financial Times, Emily Cadman (30/6/16)
Bank of England warns Brexit risks beginning to crystallise BBC News (5/7/16)
Bank of England tells banks to cut buffer to boost lending Financial Times, Caroline Binham and Chris Giles (5/7/16)
George Osborne puts corporation tax cut at heart of Brexit recovery plan Financial Times (3/7/16)
George Osborne corporation tax cut is the wrong way to start EU negotiations, former WTO boss says Independent, Hazel Sheffield (5/7/16)
George Osborne abandons 2020 UK surplus target Financial Times, Emily Cadman and Gemma Tetlow (1/7/16)
George Osborne scraps 2020 budget surplus plan The Guardian, Jill Treanor and Katie Allen (1/7/16)
Osborne abandons 2020 budget surplus target BBC News (1/7/16)
Brexit and the easing of austerity BBC News, Kamal Ahmed (1/7/16)
Osborne Follows Carney in Signaling Stimulus After Brexit Bloomberg, Simon Kennedy (1/7/16)

Questions

  1. Explain the measures taken by the Bank of England directly after the Brexit vote.
  2. What will determine whether the Bank of England engages in further quantitative easing beyond the current £385bn of asset purchases?
  3. How does monetary policy easing (or the expectation of it) affect the exchange rate? Explain.
  4. How effective is monetary policy for expanding aggregate demand? Is it more or less effective than using monetary policy to reduce aggregate demand?
  5. Explain what is meant by (a) capital adequacy ratios (tier 1 and tier 2); (b) countercyclical buffers. (See, for example, Economics 9th edition, page 533–7 and Figure 16.2))
  6. To what extent does increasing the supply of credit result in that credit being taken up by businesses and consumers?
  7. Distinguish between rules-based and discretionary fiscal policy. How would you describe paragraph 3.5 in the Charter for Budget Responsibility?
  8. Would you describe George Osborne’s proposed fiscal measures as expansionary or merely as less contractionary?
  9. Why is the WTO unhappy with George Osborne’s proposals about corporation tax?
  10. What is the Nash equilibrium of countries seeking to undercut each other’s corporation tax rates?

Some of the largest companies around the world operate in multiple locations. This allows them to take advantage of wider markets, cheaper transport and of course, lower taxes. In many cases, we see companies selling in one country, but locating their Headquarters in another, where tax rates are cheaper and hence their tax bills are lower. Much criticism has been levelled at such companies, who are accused of not paying their fair share in tax. There has been a crackdown on these companies and the UK is playing a leading role in this tightening of tax laws. Google is the latest company to face a large payment in backdated taxes.

This is a company with a complex structure, which has involved Bermuda as a key location, with its zero rate of corporation tax and a Irish European base. Though locating its business in different countries is legal, it has now agreed to pay HMRC £130 million in back taxes from 2005, following a 6 year investigation. Google will also change its accounting system such that it pays more tax in Britain for sales in this country.

Google may be the first in a line of companies making such changes to its accounting practices following a global drive to tackle the low levels of taxes paid by these large companies. This change in tax rules may bring welcome relief to government coffers, though criticisms remain about the ‘real’ figure that Google owes. As an example of this: in 2013, Google’s UK revenues were $5.6bn. Yet it only paid £20.5m in tax on its UK profits. The Head of Google Europe, Matt Brittin said:

“The rules are changing internationally and the UK government is taking the lead in applying those rules so we’ll be changing what we are doing here. We want to ensure that we pay the right amount of tax.”

Mr Brittin was clear in saying that these back dated taxes are not evidence that they had been paying too little tax in previous years. He confirmed that they were abiding by tax laws at the time and that tax laws are now changing and hence so will the amount of tax they pay. He continued:

“I think there was concern that international companies were paying only in respect of profits that they make and those were the rules and the pressure was to see us pay in respect of the sales we make to UK customers – and the same for other companies…So, we are making a change because we want to continue to comply with the rules and the rules are changing.”

As the push to tighten tax laws changes, with firms paying more tax on sales as well as profits, we may observe more companies changing their accounting structures. The OECD has taken a big step in simplifying international tax laws and the coming years will tell us just how big an impact this will have and whether companies such as Google will face tax bills in other European countries as well. The following articles consider this taxing matter.

Google agrees £130m UK tax deal with HMRC BBC News, Kamal Ahmed (23/01/16)
Google strikes £130m back tax deal Financial Times, John Gapper (22/01/16)
Google strikes deal with UK tax authority Wall Street Journal, Sam Schechner and Stephen Fidler (23/01/16)
Google agrees to pay HMRC £130m in back taxes The Guardian, Kevin Rawlinson (23/01/16)
Google tax labelled ‘derisory’ by Labour’s John McDonnell BBC News (23/01/16)
Google to pay £130 million UK back taxes, critics want more Reuters, Tom Bergin (23/01/16)
Google to pay UK £130m in back taxes The Telegraph (22/01/16)
Google says it will pay £130m in back taxes Independent, Adam Barnett (23/01/16)
Google ‘agrees’ to pay £130m in extra UK tax after outrage when it coughed up just £20m on UK sales of nearly £4bn Mail Online, Imogen Calderwood (22/01/16)
Google agrees to pay $185 million in UK tax settlement Bloomberg, Brian Womack (23/01/16)

Questions

  1. What is the difference between a tax on sales and a tax on profits?
  2. How can companies legally avoid tax? Do you think they have a moral duty to pay tax?
  3. If firms face higher rates of taxation, how will this affect their costs and profits?
  4. Why are the larger multinationals, such as Google more able to engage in tax avoidance schemes?
  5. Do you think the problem of tax avoidance is one of the negative consequences of globalisation?
  6. Is the criticism about the ‘low’ amount of taxes paid to HMRC justified?
  7. The OECD has taken a leading role in tightening international tax policy. Do you think this will negatively impact the competitiveness of the global market place?
  8. What are the costs and benefits to a country of having a low rate of corporation tax?

On Monday 23rd November, the US based pharmaceutical business Pfizer (producer of Viagra) announced that it had reached a $160 billion deal to acquire the Irish based pharmaceutical business Allergan (producer of Botox). If it is successful it will be the third largest deal in takeover history.

In a previous blog on this website a number of reasons were discussed to explain why businesses may engage in mergers and acquisitions (M&As) Are large mergers and acquisitions in the interests of the consumer . These include market power, access to growing markets, economies of scale and reducing x-inefficiency. One of the interesting things about the Pfizer and Allegan deal is the importance of another factor that was not discussed in the article – tax avoidance.

Rates of corporation tax vary considerably between countries and may deter some businesses from operating in the US where it is at the relatively high level of 35%. This compares with a rate of 20% in the UK, 12.5% in Ireland and 0% in Bermuda. The global average rate is 23.7% whereas the average across EU countries is 22.2%.

However, a far bigger incentive for a US firm to merge with or acquire businesses in other countries is the unusual way the US authorities tax profits. Most countries use a territorial system. This means that tax is only paid on the profit earned in that country. For example if a UK multinational business has subsidiaries in other countries it only pays corporation tax in the UK on profits earned in the UK. The profits earned by its subsidiary businesses would be taxed at the rate set by the government in the country where they were located.

The US authorities use a worldwide system. This means that profits earned by a subsidiary in another country are also taxed in the US. This is best explained with the help of a simple numerical example.

Assume a US multinational earns $100,000 in profits from a subsidiary based in Ireland. These profits will be taxed in Ireland at the rate of 12.5% and the company would have to pay $12,500 to the Irish government. If that profit was returned to the US it would be taxed again at a rate of 22.5%: i.e. 35% – 12.5%. The company would have to pay the US authorities $22,500.The worldwide system means that the total rate of tax paid by the firm is 35% but it is split between two different countries. If the territorial system was used, the firm would only pay the $12,500 to the Irish government.

So how could M&As change things? If an M&A enables a US multinational business to change its country of incorporation (i.e. move the address of its headquarters) from the US to another country that operates a territorial system its payments will fall. This is sometimes referred to as tax inversion. As the Bloomberg columnist Matt Levine stated:

If we’re incorporated in the U.S., we’ll pay 35 percent taxes on our income in the U.S. and Canada and Mexico and Ireland and Bermuda and the Cayman Islands, but if we’re incorporated in Canada, we’ll pay 35 percent on our income in the U.S. but 15 percent in Canada and 30 percent in Mexico and 12.5 percent in Ireland and zero percent in Bermuda and zero percent in the Cayman Islands.

As a result of the merger with Allergan, Pfizer will move the address of its headquarters to Ireland even though its global operations and executives will still be based in New York. It has been estimated that this will generate a one off tax saving of $21 billion as Pfizer would avoid having to pay US taxes on $128 billion of profits generated by its non US subsidiaries.

A number of US politicians have condemned the proposed deal. For example Hilary Clinton stated:

This proposed merger, and so called inversions by other companies, will leave US taxpayers holding the bag.

Twenty US companies have moved their headquarters to countries that operate a territorial system of taxation since 2012. These include Burger King’s move to Canada and Medtronic’s move to Ireland.

The US government has tried to tighten the rules but the two major parties disagree about how to deal with the problem.

Articles

Pfizer Seals $160bn Allergan deal to create drugs giant BBC News,(23/11/15)
Pfizer’s $160bn Allergan deal under pressure in the US BBC News,(24/11/15)
Pfizer set to buy Allergan in $150bn historic deal The Telegraph,(23/11/15)
Pfizer and Allergan poised to announce history’s biggest healthcare merger-corporate-tax The Guardian,(22/11/15)
Pfizer takeover: what is a tax inversion deal and why are they so controversial? The Guardian,(23/11/15)

Questions

  1. The newly merged business would jump above Johnson and Johnson to become the world’s largest biotech and pharmaceutical company in the world. Who are the other biggest eight Biotech and pharmaceutical businesses in the world?
  2. What exactly is a subsidiary? Give some real-world examples.
  3. How have the US authorities changed the rules in an attempt to deter tax inversions?
  4. Assume that a US multinational makes $1 million profit in the US and $1 million profit from its subsidiary in Ireland. Explain how changing its country of incorporation from the US to Ireland will alter the amount of corporation tax that it has to pay.