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1、U N I T E D N AT I O N S C O N F E R E N C E O N T R A D E A N D D E V E L O P M E N TUNCTADUNITED NATIONSINTERNATIONAL TAX REFORMS AND SUSTAINABLE INVESTMENTThe contents of this report must not be quoted or summarized in the print, broadcast or electronic media before9 June 2022, 12:00 GMT.(08:00 N
2、ew York, 14:00 Geneva, 15:00 Nairobi)EMBARGO2022WORLD INVESTMENT REPORTGeneva, 2022U N I T E D N AT I O N S C O N F E R E N C E O N T R A D E A N D D E V E L O P M E N TINTERNATIONAL TAX REFORMS AND SUSTAINABLE INVESTMENT2022WORLD INVESTMENT REPORTISBN 978-92-1-113049-2eISBN 978-92-1-001543-1Print I
3、SSN 1020-2218Online ISSN 2225-1677 Sales No. E.22.II.D.20 2022, United NationsAll rights reserved worldwideRequests to reproduce excerpts or to photocopy should be addressed to the Copyright Clearance Center at . All other queries on rights and licences, including subsidiary rights, should be addres
4、sed to: United Nations Publications405 East 42nd StreetNew York, New York 10017United States of AmericaEmail: publicationsun.orgWebsite: https:/shop.un.orgThe designations employed and the presentation of material on any map in this work do not imply the expression of any opinion whatsoever on the p
5、art of the United Nations concerning the legal status of any country, territory, city or area or of its authorities, or concerning the delimitation of its frontiers or boundaries.Mention of any firm or licensed process does not imply the endorsement of the United Nations.This publication has been ed
6、ited externally.United Nations publication issued by the United Nations Conference on Trade and Development.UNCTAD/WIR/2022iiiPrefacePREFACEGlobal flows of foreign direct investment recovered to pre-pandemic levels last year, reaching $1.6 trillion. Cross-border deals and international project finan
7、ce were particularly strong, encouraged by loose financing conditions and infrastructure stimulus. However, the recovery of greenfield investment in industry remains fragile, especially in developing countries. This fragile growth of real productive investment is likely to persist in 2022. The fallo
8、ut of the war in Ukraine with the triple food, fuel and finance crises, along with the ongoing COVID-19 pandemic and climate disruption, are adding stresses, particularly in developing countries. Global growth estimates for the year are already down by a full percentage point. There is significant r
9、isk that the momentum for recovery in international investment will stall prematurely, hampering efforts to boost finance for sustainable development.The World Investment Report supports policymakers by monitoring global and regional investment trends and national and international investment policy
10、 developments. The report reviews investment in the Sustainable Development Goals and in climate change mitigation and adaptation. It also looks at sustainable finance trends in capital markets and among institutional investors.The coming years will see the implementation of fundamental reforms in i
11、nternational taxation. These reforms are expected to have major implications for investment policy, especially in countries that make use of fiscal incentives and special economic zones. The report of this year provides a guide for policymakers to navigate the complex new tax rules and to adjust the
12、ir investment strategies.I commend this report to all engaged in promoting investment in sustainable development. Antnio Guterres Secretary-General of the United NationsivWorld Investment Report 2022 International tax reforms and sustainable investmentThe global environment for international investm
13、ent changed dramatically with the onset of the war in Ukraine, which occurred while the world was still reeling from the impact of the pandemic. The war is having effects well beyond its immediate vicinity, causing a cost-of-living crisis affecting billions of people around the world, with rising pr
14、ices for energy and food reducing real incomes and aggravating debt stress. Investor uncertainty and risk aversity could put significant downward pressure on global FDI this year.The effects on investment flows to developing countries in 2022 and beyond are difficult to anticipate. Apart from direct
15、 effects on countries in Central Asia with close investment ties in the region, the impact on others will be mostly indirect and depend on the extent of their exposure to the triple crisis in food, fuel and finance caused by the conflict and their consequent economic and political instability key de
16、terminants of international private investment. If the past is an indication, the last time food prices were this high during the 20072008 food crisis there were riots in more than 60 countries.The outcome will be of enormous significance for development prospects. The need for investment in product
17、ive capacity, in the Sustainable Development Goals (SDGs) and in climate change mitigation and adaptation is enormous. Current investment trends in these areas are not unanimously positive. Although global FDI flows rebounded strongly in 2021, industrial investment remains weak and well below pre-pa
18、ndemic levels, especially in the poorest countries; SDG investment project finance in infrastructure, food security, water and sanitation, and health is growing but not enough to reach the goals by 2030; and investment in climate change mitigation, especially renewables, is booming but most of it re
19、mains in developed countries and adaptation investment continues to lag well behind. Worryingly, some emerging indicators suggest that the war in Ukraine could become a setback in the energy transition, with increased fossil fuel production in countries previously committed to reducing emissions. In
20、 the first quarter of 2022, most of the 5,000 largest multinational enterprises revised downward their earnings forecasts for 2022. Alarmingly, while extractive industries revised upwards their expected earnings, with oil and gas at +22 per cent and coal at +32 per cent of expected earnings, renewab
21、le energy companies released downward revisions of an average of -22 per cent of expected earnings, lending credence to the intuition that current conditions risk reversing years of progress towards investing in sustainable energy. This is especially worrying as global CO2 emissions from energy comb
22、ustion and industrial processes rebounded in 2021 to reach their highest ever annual level.To achieve the SDGs it is imperative that more funds are channeled to where they are most needed, on the ground, in developing countries. But also an important effort will have to come from domestic resource m
23、obilization. From that perspective, the ongoing international tax reforms led by the G20 and the OECD, which we study extensively in this report, are a major step forward. They aim to ensure that multinationals pay their fair share of taxes where they operate, and they have the potential to give a s
24、ignificant boost to tax revenues in developing countries. FOREWORDvRebeca Grynspan Secretary-General of UNCTADForewordHowever, the war in Ukraine has further complicated domestic resource mobilization in developing countries, already worsened by the COVID-19 pandemic and the increased frequency of n
25、atural disasters in the context of climate change. In the midst of rising and unsustainable debt levels, without adequate multilateral mechanisms for restructuring, countries are being forced to reduce their fiscal space at a time when they should be increasing it. The International Labour Organizat
26、ion suggests that the social protection financing gap stands at $1.2 trillion per year in developing countries, part of the $4.3 trillion we at UNCTAD estimate as the yearly gap in SDG financing. And even with food and energy import bills, and worsening costs of borrowing due to higher interest rate
27、s, developing countries primary fiscal balance has shrunk by $315 billion since the start of the war.That is why international investment plays a critical complementary role to domestic public investment. And the new tax rules will affect how countries have traditionally promoted and often competed
28、for international investment, through low tax rates, fiscal incentives and special economic zones. The tax reforms are an opportunity for developing countries, not only from a revenue perspective, but also from an investment attraction perspective. Strategically, tax competition will decrease. Pract
29、ically, the need to review the investment promotion toolkit is a chance to make costly incentives more sustainable. There will be challenges. Developing countries face constraints in their responses to the reforms, because of a lack of technical capacity to deal with the complexity of the tax change
30、s, and because of investment treaty commitments that could hinder effective fiscal policy action. The international community has the obligation to help. It can do so through technical assistance, by agreeing a solution to problems caused by international investment agreements, and by putting in pla
31、ce safeguards that protect the tax revenues of the poorest countries. These efforts should be part of a broader multilateral endeavor towards reining in illicit financial flows, especially in the developing world. This report points the way.It is important that we act now. Even though countries face
32、 very alarming immediate problems stemming from the cost-of-living crisis, it is important we are able to invest in the long term. Because the short term and long term start at the same time. And the time is now.viWorld Investment Report 2022 International tax reforms and sustainable investmentACKNO
33、WLEDGEMENTSThe World Investment Report 2022 was prepared by a team led by James X. Zhan. The team members included Richard Bolwijn, Bruno Casella, Joseph Clements, Berna Dogan, Hamed El Kady, Kumi Endo, Anastasia Leskova, Massimo Meloni, Anthony Miller, Abraham Negash, Yongfu Ouyang, Diana Rosert, A
34、melia U. Santos-Paulino, Changbum Son, Astrit Sulstarova, Claudia Trentini, Joerg Weber and Kee Hwee Wee. Research support and inputs were provided by Gregory Auclair, Hamidreza Bakhtiarizadeh, Magdalena Bulit Goi, Joo de Camargo Mainente, Malou Celander, Antoine Cornevin, Juliette Gailly, Tiffany G
35、rabski, Vicente Guazzini, Maxime Ladrire, Corli Le Roux, Iana Miachenkova, Josef Ostansk, Hayley Marie Pallan, Sang Hyun Park, Lisa Remke, Samuel Ringier, Rita Schmutz, Baptiste Souillard, Irina Stanyukova, Ilan Strauss, Yihua Teng and Anqi Wang. Comments and contributions were provided by Yoseph As
36、melash, Chantal Dupasquier, Isabel Garza Rodriguez and Paul Wessendorp, as well as the Office of the Secretary General. Statistical assistance was provided by Mohamed Chiraz Baly and Bradley Boicourt. IT assistance was provided by Chrysanthi Kourti. The manuscript was copy-edited by Lise Lingo. The
37、design of the charts and infographics, and the typesetting of the report were done by Thierry Alran, assisted by Alexandra Sonia Garcs. Production of the report was supported by Elisabeth Anodeau-Mareschal and Katia Vieu. Additional support was provided by Nathalie Eulaerts and Sivanla Sikounnavong.
38、 Michael Keen acted as principal advisor on the theme chapter of the report. The theme chapter also benefited from the collaboration with the team at the WU Global Tax Policy Centre of Vienna University of Economics and Business led by Jeffrey Owens, including Ivan Lazarov, Belissa Ferreira Liotti,
39、Ruth Wamuyu Maina and Joy Waruguru Ndubai. At various stages of the preparation of the theme chapter, in particular during the kick-off event at the World Investment Forum and various expert meetings organized to discuss drafts, the team benefited from comments and inputs received from external expe
40、rts: Flurim Aliu, David Bradbury, Julien Chaisse, Alex Cobham, Michael Devereux, Lorraine Eden, Javier Garcia-Bernardo, Ana Cinta Gonzalez Cabral, Tibor Hanappi, Liselott Kana, Anita Kapur, Petr Jansk, Michael Lennard, Pierce OReilly, Zahira Quattrocchi, Augustin Redonda, Tove Maria Ryding and Logan
41、 Wort. The team is grateful for advice, input and comments at all stages from colleagues in international organizations and other experts, including Vincent Beyer, Martin Dietrich Brauch, Abdul Muheet Chowdhary, Sabrine Marsit, Suzy H. Nikima, Marcelo Olarreaga, Joshua Paine, Mara Florencia Sarmient
42、o, Alessandro Turina, Christian Volpe Martincus and Sebastian Wuschka. Numerous officials in central banks, national government agencies, international organizations and non-governmental organizations also contributed to the report. viiTABLE OF CONTENTSPREFACE . . . . . . . . . . . . . . . . . . . .
43、 . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iiiFOREWORD . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ivACKNOWLEDGEMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . viABBREVIATI
44、ONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .xKEY MESSAGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . xiCHAPTER I. GLOBAL INVESTMENT TRENDS AND PROSPECTS . . . . . . . . . . . . . .1A . INVES
45、TMENT TRENDS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21. Global trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22. Trends by geography . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .
46、 . . . . . . . . . . . . .73. Trends by type and sector . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .22B . SDG AND CLIMATE CHANGE INVESTMENT TRENDS . . . . . . . . . . . . . . . . . . . .261. SDG investment trends . . . . . . . . . . . . . . . . . . . . . . . . . .
47、. . . . . . . . . . . . . . . .262. Climate change and investment . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .32C . INTERNATIONAL PRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .391. Key indicators of international production . . . . . . . . .
48、 . . . . . . . . . . . . . . . . . . . .392. Internationalization trends of the largest MNEs . . . . . . . . . . . . . . . . . . . . . . . . .403. Internationalization trends of digital MNEs . . . . . . . . . . . . . . . . . . . . . . . . . . . .424. Internationalization trends of SMEs . . . . . . .
49、 . . . . . . . . . . . . . . . . . . . . . . . . . .47CHAPTER II. RECENT POLICY DEVELOPMENTS AND KEY ISSUES . . . . . . . . . . .53INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .54A . NATIONAL INVESTMENT POLICIES . . . . . . . . . . . .
50、. . . . . . . . . . . . . . . . . . . .561. Overall trends . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .562. M&A controls affecting foreign investors . . . . . . . . . . . . . . . . . . . . . . . . . . . . .63B . INTERNATIONAL INVESTMENT POLICIES . .