Using EU transaction log and Orbis ownership data, I show that multinational groups shift EU ETS allowances within the group at year-end, from stricter to more lenient accounting jurisdictions. The pattern is consistent with regulatory arbitrage rather than real compliance needs.
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Presented at VfS and IIPF 2024; scheduled for the World Inequality Conference 2026.
Abstract
This study presents preliminary evidence that the European Emission Trading Scheme (EU ETS) is exploited by multinational companies to artificially shift profits between European countries. Specifically, using the EU transaction log and Orbis ownership data, I highlight abnormally high levels of internal trade in emission allowances at year-end—despite the April surrender deadline—within firms under the same Global Ultimate Owner (GUO). This activity is especially marked in transactions involving firms without actual emission certificate needs. Towards the year-end, allowances are moved from subsidiaries in strict accounting jurisdictions to those in lenient ones, indicating regulatory arbitrage. These patterns hint to a potential misuse of the EU ETS for financial manipulation rather than emission reduction.