“…Other techniques include, but are not limited to: thin capitalization and inter-company loans, in which subsidiaries abroad can be used to create a system of loans and debt that allow parent companies to deduct interest payments if the subsidiary is located in a country, like the Netherlands, where such interest payments to the subsidiary are not taxed (Evertsson, 2016a; Nedham, 2013; Palan et al, 2010; Taylor and Richardson, 2012; Walsh and Ryan, 1997); paying for intangibles (Evertsson, 2016a; Nedham, 2013), including the shifting of royalties between countries to avoid taxation (Dharmapala and Hines, 2009); hybrid entities for investment (Evertsson, 2016a; Nedham, 2013); no reporting of country-specific revenues, known as country-by-country reporting (Hope et al, 2013; Palan et al, 2010; Seabrooke and Wigan, 2016; Wójcik, 2015) and patent boxes (Evers et al, 2015; Miller and Pope, 2015), which reduce the effective average tax rate on investments that qualify to be included in such a box. The latter technique can result in negative effective tax rates in countries such as Belgium, France, Spain and Hungary.…”