By Mark Bou Mansour
A US-backed global gag order preventing governments from revealing the names of multinational corporations found shifting billions into tax havens has caused countries to miss out on over US$475 billion in corporate tax from 2016 to 2021, the Tax Justice Network’s research reveals today.
The tax lost is far more than the amount urgently needed for the $300 billion climate finance fund that countries committed to in 2024. “Governments claim there isn’t enough money for climate action but as this report clearly shows, there is—it is in the wrong hands,” said Greenpeace International’s Nina Stros.
A key driver of the losses is a dramatic escalation in tax abuse by US multinational corporations set loose by Trump’s 2017 Tax Cuts and Jobs Act, the research finds. US multinational corporations are now shifting twice as much profit out of the countries where they operate in and into the US, but are paying even less tax in the US than they were before Trump’s tax cuts were introduced.
They are responsible for 29 per cent of all corporate tax losses suffered yearly by all countries.
The biggest loser by far to US multinationals’ tax abuse is the US itself—which has long backed the decision to keep the public in the dark on the profit shifting activities of multinational corporations. The EU and Australia began to partially lift the global gag order locally this year despite increasingly aggressive lobbying from US multinationals in particular. In June this year, all countries but the US committed in a UN outcome document to take steps towards lifting the global gag order by evaluating the option of a global public database for the reports in the future.
Efforts to adequately tax US and other multinational corporations were front and center in November at a negotiating session in Nairobi where countries continued work on a world-first United Nations tax convention. Transparency measures to ensure fair access to information are part of the package, and countries can now more ambitiously commit to lift the global gag order fully, ensuring every member state—and their citizens—would benefit.
The convention is largely seen as countries’ last resort to push back against the new Trump administration’s sweeping threats and attacks on the tax sovereignty of nations—that is, on the right of a nation to decide who to tax within its borders, how much and what for.
The work at the UN and the work of the Trump administration present two competing visions on how to fill the vacuum left by this year’s collapse of a 100-years-long consensus in international tax—a collapse triggered by both the start of formal negotiations on a UN tax convention to replace the older order and by the Trump administration’s exploding of the decades-long, US-dominated OECD process.
On the one side, the Trump administration is attempting to enforce a pre-League of Nations, might-is-right approach where a corporation operating globally can only be taxed by the country in which it is headquartered—a complete reversal to the US’s position declared in a presidential memorandum on day one of Trump’s second term.
On the other side, the UN tax convention would ideally require corporations operating globally to be taxed proportionally by the countries in which they operate and make their profits, based on ensuring a “fair allocation of taxing rights” between countries that respects and bolsters countries’ tax sovereignty—a commitment agreed to last year in the pre-negotiations phase of the work.
The Tax Justice Network identifies two factors that will help determine which vision wins out. First, fully lifting the global gag order, by implementing public country by country reporting, is a necessary step to securing the transparency needed to be able to measure and to ensure fair allocations. Second, countries must replace the 100-year-old “pay where you say” approach used to tax multinational corporations with a “pay where you play” approach—by implementing a unitary tax approach—so that fair allocations can be based on where multinational corporations genuinely operate instead of where they declare their profits on paper.
Previous research has demonstrated the hidden and sometimes deadly costs of weakened tax sovereignty, linking global tax abuse by corporations and the superrich to over 60,000 preventable deaths among children under the age of five every year. Human Rights Watch’s Sarah Saadoun said: “For many countries, revenue losses under the current international tax system are not just a fiscal issue—they are a human rights crisis.”
Human Rights Watch, Greenpeace, global union federation PSI, Patriotic Millionaires UK, renowned economists and tax justice campaigners from around the world commenting on the Tax Justice Network’s research findings today are calling on governments to commit to the UN tax convention and to tax transparency on multinational corporations.
Tax Justice Network Chief Executive Alex Cobham said: “The world is at a fork in the road. One path leads to tax subjugation under Trump and US multinationals, while the other leads to a collective defence of tax sovereignty at the UN that protects every country’s taxing rights.
“We’re all being plundered at a catastrophic rate, but instead of Vikings or Conquistadors violently raiding villages, it’s US corporations quietly robbing our treasuries, including that of the US itself. Every year, US multinationals rob the world of an amount of tax that is worth twice all the gold and silver that Spanish colonisers plundered out of the Americas over a span of 150 years.
“Every teacher fired, every nurse denied better pay, every struggling worker taxed more in the name of ‘balancing the books’ ought to be outraged today by their government’s decades-long tax surrender. By reclaiming those revenues, we can invest in our societies so we can all live better lives. Democracy started as a fight for tax rights: no taxation without representation. Our message to our governments is clear: get up and fight for our tax rights.”
The biggest losers
The biggest loser to the global gag order is the US itself, which is being urged by US multinational corporations to preserve. Among the other biggest losers are countries like the UK, Germany and France where heated debates on balancing budgets and paying for public services have been ongoing.
Some of the biggest losers, and the amount of corporate tax they lost from 2016 to 2021 to the global gag order, are listed here:
- US: US$158.5 billion
- France: €27.3 billion (US$32.3 billion)
- Germany: €25.7 billion (US$30.3 billion)
- India: ₹1.805 trillion (US$24.4 billion)
- UK: £10.8 billion (US$14.8 billion)
- Mexico: MEX$254 billion (US$12.5 billion)
- South Africa: 9 billion (US$2.8 billion)
Mark Bou Mansour is Director of Communications at Tax Justice Network.
Source: taxjustice.net, November 3, 2025