The same gap, six tax systems

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Figures current as of·Corrections


A small business is taxed by one country. A multinational chooses among many. That single difference produces roughly the same outcome in six very different tax systems, and each of the six has a public record that shows exactly how.

This section is not another rate comparison. The headline arithmetic lives elsewhere on this site: a profitable small company faces a corporate rate of up to 25% to 30% depending on where it trades, while several of the world's largest companies have paid low single digits, legally. What these pages do instead is follow that gap into each jurisdiction and show how it actually works there: which structures got dragged into open court or a Parliamentary hearing, how much money the country loses, what its anti-avoidance regime has tried to do about it, and what an ordinary business there can legitimately claim.

Each country lost and inflicted a measurable amount. The figures below are the loss each country suffers to cross-border corporate tax abuse, from the Tax Justice Network's State of Tax Justice 2024 (data year 2021), for the five countries pinned in that edition. Several of these same countries also inflict large losses on others through their own financial and territorial structures, which is the part the league table makes explicit. South Africa is not separately pinned in that edition, so its loss is given from a different primary source, the UNU-WIDER research on profit shifting, and labelled as such.

The United Kingdom. Home of the 2012 Public Accounts Committee hearings that put three large multinationals (a global coffee chain, an online retailer and a search-and-advertising group) on the record and triggered the Diverted Profits Tax. Loses about $16.9bn a year, inflicts about $23.5bn on others. Read the UK page

The United States. Where a Senate subcommittee laid out a major US technology group's offshore architecture in 2013, and whose own minimum-tax regime (GILTI, now renamed NCTI, plus BEAT and FDII) became the reason it refused to sign up to the global deal. The biggest absolute loser of the five, at about $32.6bn a year. Read the US page

Canada. Where a Big Four firm's Isle of Man scheme exposed how the system protects the advisers as much as the avoiders, and where a digital-services tax was scrapped overnight under US pressure. Loses about $8.9bn, but inflicts about $31.2bn on others. Read the Canada page

Australia. Built two of the toughest targeted anti-avoidance laws in the world, then watched its own consulting-firm-to-government pipeline leak the plans for one of them. Loses about $22.1bn a year, around 1.3% to 1.4% of GDP, one of the heaviest relative hits of any rich country. Read the Australia page

India. Fought two landmark companies, a telecoms group and an energy group, with a retrospective tax, lost both in international arbitration, and repealed the law. Now polices the Mauritius route and a general anti-avoidance rule that a 2026 Supreme Court ruling has just sharpened. Loses about $21.4bn a year. Read the India page

South Africa. Has had a statutory general anti-avoidance rule, sections 80A to 80L of the Income Tax Act, since 2006, and a tax authority that has grown more assertive about impermissible avoidance. Its loss is not separately pinned in the State of Tax Justice 2024 edition used here; the best country-specific estimate, from UNU-WIDER, puts the revenue lost to multinational profit shifting at about 4% of corporate income tax receipts, roughly R7bn a year, with the largest multinationals shifting about 78% of their profits offshore. Read the South Africa page

Sources

  1. 01Tax Justice Network, State of Tax Justice 2024
  2. 02UK Corporation Tax rates and allowances, HMRC
  3. 03IRS Publication 542, Corporations
  4. 04UNU-WIDER, The impact of tax havens on South African revenue