etika beteiligt sich auch in diesem Jahr an den Make Amazon Pay-Protesten (Foto oben von 2023). Amazon steht nicht nur für die Ausbeutung von Arbeitnehmerrechten und das Ruinieren von Mitbewerbern, sondern auch für aggressive Steuervermeidung. Dass der europäische Hauptsitz des Unternehmens ausgerechnet bei uns in Luxemburg liegt, ist kein Zufall.
2021 veröffentlichte die City University London die Studie The Amazon Method, die Amazons Steuerpraktiken in Luxemburg genauer untersuchte. Die Studie zeigt, wie zentral der hiesige Unternehmenssitz für die weltweite Steuervermeidungsstrategie des Konzerns ist.
Wir haben uns diese Woche mit dem Wirtschaftswissenschaftler und Co-Autor der Studie, Ronen Palan, unterhalten, um Genaueres zu erfahren.
Amazon recently announced that it invested one billion euros in Luxembourg last year. This move was presumably intended to shield the company from criticism of its tax practices. Is Amazon making a good argument here, in your opinion?
"Of course not. Investing doesn’t justify not paying taxes. And when they say they’ve invested, it could mean many things, but we don’t know what it actually entails. This is the language companies use to appear transparent, but they are not. It’s a spin."
In your study The Amazon Method, you describe Luxembourg as the centerpiece of Amazon’s global tax avoidance strategy. Can you explain why Luxembourg plays such a central role?
"First of all, there is no single ’Amazon.’ Legally speaking, it’s a network of subsidiaries. In our study, we looked closely at these subsidiaries and how the company is organized. We found that Amazon’s worldwide foreign operations are largely structured through Luxembourg, but we couldn’t fully explain why. Something about Luxembourg makes things very easy for them."
What is it?
"We are not entirely sure. One thing we found is that Amazon uses a legitimate U.S. tax mechanism called tax deferral. This allows companies to transfer losses made abroad to the U.S. parent company, reducing its tax liability in the U.S. Our study shows that most of Amazon’s international losses are aggregated in Luxembourg. These losses are then used to offset taxes in the U.S."
Is the primary fiscal function of Amazon’s Luxembourg location to save taxes in the U.S. rather than in Europe?
"It’s hard to say. My suspicion is that Amazon, as a very sophisticated company, is not paying taxes anywhere. So, in a way, everybody suffers. It’s not a simple U.S.-versus-Europe issue but part of a global strategy where Luxembourg plays a major role."
In addition to losses, Amazon also transfers profits to Luxembourg. How does that work?
"There are two main methods. First, a Luxembourg parent company can lend money to a subsidiary in another country. The interest on the loan is tax-deductible in the subsidiary’s country but becomes income for the Luxembourg parent. Second, the Luxembourg entity can license intellectual property to a subsidiary. The subsidiary pays royalties or dividends back to Luxembourg. These payments are often taxed very lightly, or not at all."
Your study doesn’t specify how much money Amazon has saved through these tax practices. Why not?
“Our study showed that Luxembourg is at the heart of Amazon’s worldwide expansion. However, we couldn’t determine exactly how much Amazon has saved. The company has created such an opaque structure, with Luxembourg’s help, that it’s almost impossible to know. Anyone who claims to know the exact figures, except for Amazon insiders, is guessing."
You argue that this opacity is deliberate. Why?
"Nothing in these structures is random. Companies like Amazon plan everything carefully, with lawyers ensuring that every step is intentional. Is it only planed purely for tax avoidance purposes? I’m not sure. While tax avoidance is a major driver, other goals, like limiting liability or bypassing financial regulations, also play a role. Luxembourg is very effective at enabling opacity."
What could be done to prevent this?
"The key is better reporting, even if companies often claim that revealing too much would hurt their competitiveness. The less clear the rules are, the easier it is for companies to exploit them through regulatory arbitrage."
Your study highlights the impact of Amazon’s tax practices on public finances. What are the consequences for affected countries?
"First of all, running a modern state is expensive. And if the corporate sector doesn’t pay its share, somebody has to fill the gap. What we see is a squeeze on the middle classes, who have to pay more taxes. At the same time, the quality of public services declines, and taxes for individuals keep rising. It’s a transfer of wealth from the poor and the middle class to the rich.
I see this directly tied to figures like Trump and the rise of the right. People say, ‘The government is in the hands of big corporations. They don’t pay taxes. We have to pay more and more, and we need someone to protect us.’ They don’t understand the complexities—things like arbitrage or tax structures—but they do understand that they’re paying more and getting less. So, anyone offering them an anti-establishment narrative seems more plausible than the establishment, which appears unwilling to fix the problem. They often vote for the wrong people, in my view, but I can understand their frustration."
What about the Global South?
"The situation is even worse there. If you deal with such a complex entity like Amazon, even countries like Great Britian are struggling to know what is going on. How about developing countries?
Secondly, what is often forgotten is that the value creation of products takes place in developed countries. For example, with coffee, only around 3% of the price paid in the shop goes to the producing countries. The rest covers costs like branding, legal services, and advertising—activities that take place elsewhere. These countries lose out not only on the revenue from their raw materials but also on tax income because the value-added happens abroad."
Your study calls for stronger regulation, such as a global minimum tax. Will the recently introduced 15% minimum tax make a difference?
"It might help, but it will likely lead to new tax avoidance strategies. Companies like Amazon won’t simply stop. We’ll need to wait three to four years to see its full impact."
Artikel vom 28.11.2024
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