By Thomas Georges and Zorka Milin

Note: FACT will continue to monitor relevant disclosures as they are released, and may update this page.

New tax transparency requirements for publicly-traded companies are yielding fresh insights into the continued use of tax havens by major American multinationals. As a result of new accounting standards long advocated by the FACT Coalition and by investors, publicly-traded companies must now specify tax credits and other U.S. policies, as well as foreign jurisdictions that substantially lowered (or raised) their total tax expense for the year. 

The new disclosures reinforce what FACT and other tax experts have long said: the U.S. tax code continues to encourage America’s largest corporations to stash profits in tax havens. In some cases, profit shifting is associated with the offshoring of domestic jobs.

Key Takeaways from the New Disclosures:

• Major American corporations collectively reduced their tax bills by more than $11 billion through tax havens in 2025 (note that this figure is likely to be an underestimate).¹ Big Pharma companies AbbVie and Merck, along with asset management firm Apollo Global Management, each lowered their total tax expense by more than $1 billion through haven jurisdictions.
• Most of the tax haven savings are attributable to pharmaceutical and biotech companies. Just 10 pharma and biotech giants² – Abbvie, Biogen, Bristol Meyers Squibb, Eli Lilly, Gilead, Johnson & Johnson, Merck, Pfizer,³ Regeneron, and Thermo Fisher Scientific – collectively reported more savings from tax havens than the other 30 analyzed companies combined. Previous investigations by Senator Ron Wyden, as well as research and testimony by economist Brad Setser have spotlighted the questionable international tax practices of American pharmaceutical companies. In particular, these companies often use a loophole called “roundtripping” to route profits from sales to U.S. customers through foreign tax havens, at an estimated cost to U.S. revenues of $70 billion over 10 years. Proposed U.S. Senate legislation would close this loophole. 
• Around 70 percent of the tax haven savings in our analysis were booked in just four jurisdictions: Switzerland, Ireland, Puerto Rico, and the Netherlands. Notably, none of these jurisdictions have been commonly included in so-called tax haven “blacklists” or “graylists” compiled by various international organizations, raising questions about the real-world relevance of such lists.   
• U.S. international tax rules are too weak to deter profit-shifting to tax havens. Nearly all of the analyzed companies reported tax haven savings that dwarfed the impact of U.S. anti-abuse rules.⁴ Against more than $11.5 billion in aggregate tax haven savings for the 40 analyzed companies, relevant U.S. international taxes clawed back only around $3 billion.⁵ A comprehensive international tax reform package, endorsed by the FACT Coalition, was reintroduced in the House and Senate in February 2025. Similar reforms have been estimated to raise around $1 trillion in revenue over 10 years, roughly enough to pay for reversing the devastating 2025 cuts to Medicaid and food assistance programs.
• The OECD’s “Pillar Two” 15 percent global minimum tax is beginning to take a bite out of tax haven savings for some companies. For example, GE Aerospace disclosed that the benefit of its negotiated tax rate in Singapore was reduced by $121 million, while Amgen and Mastercard saw their tax benefits in Singapore reduced by $147 and $223 million, respectively. It remains to be seen to what extent such tax payments may be impacted by the so-called side-by-side agreement, which exempts U.S. corporations from some, but not all, aspects of the Pillar Two regime, with effect from 2026. 
• Meanwhile, American companies are getting out of paying a similar U.S. minimum tax, which has been effectively dismantled. The Corporate Alternative Minimum Tax, or CAMT, was intended to act as a backstop to ensure that large, profitable companies pay at least some tax, but has been eviscerated via recent regulatory changes that could be unlawful and unconstitutional. As a result, some American companies, including the oil and gas companies Apache (now APA) and Cheniere, have reported reducing or even eliminating their CAMT liability for 2025.

In addition to their continued use of tax havens, large U.S. companies are benefiting from recently-renewed and expanded tax breaks in the 2025 tax reform law. According to a tally by FACT-member ITEP, these tax breaks have reduced corporate tax bills by more than $100 billion in 2025. One particularly wasteful tax break that was expanded in 2025 – an export subsidy regime called Foreign-Derived Intangible Income (FDII, now renamed FDDEI) – saved tech giants Nvidia and Alphabet (the parent company of Google) each about $4 billion last year alone. 

As a result of both widespread use of tax havens and generous domestic corporate tax breaks, iconic American companies often pay far more tax abroad than at home: Tesla paid nearly 27 times as much tax to China as to the U.S. federal government in 2025, while ExxonMobil paid five times as much to the UAE, and Eli Lilly paid twice as much to Ireland. New by-country breakdowns of cash taxes paid are another part of the same accounting standards update as the tax haven data presented below.

Total Tax Expense Increase (Reduction), By Jurisdiction for Select U.S. Companies in 2025 ($ in Millions)

Methodological Notes

• Scope: These figures are not comprehensive, but are limited to companies and jurisdictions that are in scope, as outlined below. The analysis necessarily only covers jurisdictions that were required to be disaggregated under the relevant accounting standard, and therefore omits individual tax effects that fell below the de minimis threshold (i.e., those that increase or decrease a given company’s overall tax expense by less than ~1 percent of pre-tax global income). Such effects were folded into the “other jurisdictions” category, but could nevertheless represent significant sums for some large companies. For these reasons, the figures presented here are likely to be an underestimate. 
• Companies were selected for inclusion in this analysis if they met the following criteria:
  • U.S.-incorporated;
  • Reported at least $1 billion in global profit in 2025; and
  • Reported net tax savings effects from tax havens in 2025, as defined below.
• Our analysis omits large companies that have not yet reported because they operate on a fiscal year different from the calendar year, including Apple, Broadcom, Cisco, McKesson, Microsoft, Qualcomm, and Starbucks. FACT may update this analysis as more reports become available.
• Tax havens, for purposes of this analysis, were determined by reference to the Australian Tax Authority’s list of specified jurisdictions (International Dealings Schedule, Appendix 1), with three additions: Malta, Puerto Rico, and the United Arab Emirates. Puerto Rico is a U.S. territory, but is treated as a foreign jurisdiction for tax purposes.
• Net effects: If a company reported multiple tax effects for a given jurisdiction, those effects are presented as a net total. U.S. cross-border tax effects including GILTI and Subpart F are calculated net of relevant foreign tax credits. Other cross-border tax effects incorporated in this analysis include U.S. taxation of foreign branches, U.S. tax on foreign insurance income, and other effects that did not reach the required threshold for individual disclosure, but are disclosed as a group under “other”  cross-border tax effects. This analysis excludes FDII/FDDEI benefit where separately reported, although it may reflect some amount of FDII/FDDEI benefit that was folded into “other” cross-border tax effects because it did not meet the de minimis disaggregation threshold for a given company.

Footnotes

1. See methodological notes above. ↩︎
2. Another major pharma company, Amgen, did not disclose net tax savings from tax haven jurisdictions in 2025. However, the effect of “U.S. tax on foreign subsidiaries” and other U.S. cross-border tax effects (excluding FDII/FDDEI benefit), combined with “Credit on foreign taxes imposed on U.S. income”, collectively reduced the company’s income tax expense by $1.02 billion for the year. ↩︎
3. Similarly to Amgen, Pfizer disclosed relatively low net income tax effects from haven jurisdictions in 2025, but the effect of GILTI and Subpart F tax credits, foreign branch income, and other cross-border tax effects reduced the company’s total tax expense by about $1.55 billion for the year. These tax effects are not included in this analysis. Pfizer’s reported total tax rate for 2025 was -3.5%, a decrease from 2024 “primarily due to a favorable change in the jurisdictional mix of earnings, tax benefits related to global income tax resolutions in multiple tax jurisdictions spanning multiple tax years, and the remeasurement of deferred tax liabilities due to the enactment of the OBBBA on July 4, 2025.” ↩︎
4. In particular, the Global Intangible Low-Taxed Income, or “GILTI” regime, and Subpart F. See the methodological notes above for a more complete description of cross border tax effects integrated into this analysis. ↩︎
5. Note that we assume that Merck’s GILTI and Subpart F expense is offset by reported foreign tax credits. Merck reported $4.0 billion in combined GILTI and Subpart F expense, as well as $4.2 billion in foreign tax credits. While their disclosures do not specify which expenses those foreign tax credits offset, or by how much, their current U.S. tax expense and other reported metrics suggest that net GILTI and Subpart F liability was much lower than the reported effect on the rate reconciliation table. Relevant accounting rules permit Cross-Border Tax Effects like GILTI and Subpart F to be presented either in gross amounts or net of relevant foreign tax credits, but Merck does not disclose which presentation it has elected for these effects. With the exception of Merck, no foreign tax credits not specified to be directly attributable to GILTI or Subpart F are included in this analysis. ↩︎