In this paper, we study another approach to the profit shifting costs function of multinational profit shifting. First, we describe the modelling approaches of such costs functions and provide a synthesized analysis. More precisely, we investigate the involved resource costs that multinational firms incur through a tax-motivated reallocation of profit across tax jurisdictions. Second, we set up a simple theoretical model of a representative multinational firm within which we conceptualize our new cost function. We expand the literature by including a relationship between profit shifting costs and tax uncertainty. Furthermore, we describe the costs split, the property of our costs function and we express its parameters. Finally, we discuss our results in conjunction with the literature, emphasizing that profit shifting costs and tax uncertainty cause more concerns for developing countries than advanced economies.

This study provides empirical evidence of tax-induced profit-shifting by multinational corporations (MNCs) operating in Morocco, an underexplored developing country context characterized by notable tax arbitrage potential. Using a micro-level panel dataset of foreign-owned subsidiaries from 2014 to 2023, we employ a pseudo-ordinary least squares (POLS) framework to examine how corporate income tax (CIT) differentials affect subsidiaries’ earnings before interest and taxes (EBIT). The results indicate that higher CIT differentials significantly reduce reported profits, supporting the indirect evidence on corporate profit-shifting behaviour. Our findings also document that the effect of the CIT differential on EBIT is moderated by firm capitalization. However, contrary to investment distortion theory, subsidiaries do not reduce investment in response to higher effective capital costs. This study also assesses the impact of Morocco’s implementation of BEPS, the COVID-19 shock, and institutional quality indicators on subsidiaries’ reported EBIT. The findings highlight the strategic role of capital structure and governance in shaping MNCs’ tax-motivated behaviour. This study contributes to the literature on international taxation and corporate finance and offers important policy implications for developing economies seeking to balance revenue integrity, investment incentives, and robust anti-avoidance enforcement.