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The Allocation of Multinational Business Income: Reassessing the Formula Apportionment Option

Edited by: Richard Krever, François Vaillancourt

ISBN13: 9789403506142
Published: March 2020
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £125.00



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The Allocation of Multinational Business Income is a global guide to formula apportionment providing a comprehensive understanding of aspects of the formulary apportionment option. Although an arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book, a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States address this actively debated topic, in respect of both its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems.

What’s in this book:

Drawing on a wealth of literature considering formula apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following:

  • the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment
  • application of formula apportionment in specific sectors such as digital enterprises and the banking industry;
  • the political economy of establishing and maintaining a successful formulary apportionment regime formulary apportionment proposals for Europe
  • role of traditional tax criteria such as economic efficiency, fairness, ease of administration, robustness to avoidance and incentive compatibility
  • determining which parts of a multinational group are included in a formula apportionment unit, and
  • whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system

How this will help you:

Having a realistic appreciation of the prospects for adoption of formulary apportionment in Europe and globally, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policymakers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formula apportionment in Europe and globally and the counterarguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international tax rules.

Contents:
Introduction: Reassessing the Formulary Apportionment Option
Richard Krever & François Vaillancourt
PART I. The Story to Date
CHAPTER 1. History and Theory of Formulary Apportionment
Richard Krever & Peter Mellor
CHAPTER 2. The US States’ Experience with Formulary Apportionment
Shirley Sicilian & Joe Huddleston
CHAPTER 3. Formulary Apportionment in Canada and Taxation of Corporate Income in 2019: Current Practice, Origins and Evaluation
Michael Smart & François Vaillancourt
CHAPTER 4. The Dream Is Alive: EU Tax Policy with a Common Consolidated Corporate Tax Base and Formulary Apportionment
Joann Martens Weiner
CHAPTER 5. The Application of Formulary Apportionment to Related Entities: Lessons from the US Experience
Walter Hellerstein
PART II. Future Possibilities: Variations on the Formulary Apportionment Theme
CHAPTER 6. Is Unilateral Formulary Apportionment Better than the Status Quo?
J. Clifton Fleming, Jr., Robert J. Peroni & Stephen E. Shay
CHAPTER 7. A Framework for Assessing Business Sector Formulary Apportionment
Kerrie Sadiq
PART III. The Evolving Intersections of Arm’s Length Pricing and Formulary Apportionment and Alternatives
CHAPTER 8. Between Arm’s Length and Formulary Apportionment
Yariv Brauner
CHAPTER 9. Is Arm’s Length Profit Split Methodology Morphing into a Formulary Apportionment Hybrid: The Chinese Example
Fei Gao & Antony Ting
PART IV. Formulary Apportionment in an Evolving International Tax System
CHAPTER 10. Value Creation and the Allocation of Profits under a Formulary Apportionment System
John Vella
CHAPTER 11. Formulating the International Tax Debate: Where Does Formulary Apportionment Fit?
Itai Grinberg
PART V. Can International Tax Sharing Become Reality?
CHAPTER 12. International Tax Sharing: Can the Dream Become Reality?
Richard Bird & Jack Mintz
Index

Series: Series on International Taxation

The Taxation of Fees for Technical Services on the Basis of Article 12A UN Model ISBN 9789403542973
To be published May 2024
Kluwer Law International
£92.00
The Resolution of International Tax Disputes ISBN 9789403520889
To be published May 2024
Kluwer Law International
£75.00
Taxation of Derivatives and Cryptoassets 2nd ed ISBN 9789403523835
To be published April 2024
Kluwer Law International
£143.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed ISBN 9789403546667
Published December 2023
Kluwer Law International
£144.00
Double Non-taxation and the Use of Hybrid Entities 2nd ed (eBook) ISBN 9789403546766
Published December 2023
Kluwer Law International
£144.00
(ePub)
Buy
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea (eBook) ISBN 9789403534176
Published November 2023
Kluwer Law International
£81.00
(ePub)
Buy
Tax Treaty Dispute Resolution: Lessons from the Law of the Sea ISBN 9789403534077
Published November 2023
Kluwer Law International
£81.00
The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective (eBook) ISBN 9789403537627
Published August 2022
Kluwer Law International
£96.00
(ePub)
Buy
The Role of Tax Law in Mergers and Acquisitions: A Chinese Perspective ISBN 9789403537412
Published August 2022
Kluwer Law International
£96.00
£139.00
(ePub)
Buy
£139.00
Coordination and Cooperation: Tax Policy in the 21st Century ISBN 9789403537405
Published December 2021
Kluwer Law International
£128.00
Coordination and Cooperation: Tax Policy in the 21st Century (eBook) ISBN 9789403537603
Published December 2021
Kluwer Law International
£128.00
(ePub)
Buy
Exploring the Nexus Doctrine In International Tax Law (eBook) ISBN 9789403533643
Published May 2021
Kluwer Law International
£75.00
(ePub)
Buy
Regulation and Tax in Space (eBook) ISBN 9789403533940
Published May 2021
Kluwer Law International
£79.00
(ePub)
Buy
Exploring the Nexus Doctrine In International Tax Law ISBN 9789403533636
Published May 2021
Kluwer Law International
£75.00
Regulation and Tax in Space ISBN 9789403533933
Published May 2021
Kluwer Law International
£79.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed ISBN 9789403520612
Published July 2020
Kluwer Law International
£375.00
Permanent Establishment: Erosion of a Tax Treaty Principle 2nd ed (eBook) ISBN 9789403520643
Published July 2020
Kluwer Law International
£375.00
(ePub)
Buy
International Taxation of Banking ISBN 9789403510941
Published February 2020
Kluwer Law International
£168.00
International Taxation of Banking (eBook) ISBN 9789403510958
Published February 2020
Kluwer Law International
£168.00
(ePub)
Buy
Tax Treaty Residence of Entities ISBN 9789403513010
Published November 2019
Kluwer Law International
£108.00
Hybrid Financial Instruments, Double Non-Taxation and Linking Rules ISBN 9789403510743
Published August 2019
Kluwer Law International
£130.00
Tax and the Digital Economy: Challenges and Proposals for Reform ISBN 9789403503615
Published May 2019
Kluwer Law International
£111.00
Taxation, Virtual Currency and Blockchain ISBN 9789403501031
Published December 2018
Kluwer Law International
£96.00
International Taxation of Energy Production and Distribution ISBN 9789041191014
Published May 2018
Kluwer Law International
£159.00
Out of print
£110.00
£110.00
Winning the Tax Wars: Tax Competition and Cooperation ISBN 9789041194602
Published December 2017
Kluwer Law International
£119.00
BRICS and International Tax Law ISBN 9789041194350
Published December 2017
Kluwer Law International
£149.00
Legal Interpretation of Tax Law 2nd ed ISBN 9789041184733
Published October 2017
Kluwer Law International
£149.00
Other Income under Tax Treaties ISBN 9789041166104
Published September 2015
Kluwer Law International
£241.00
General Anti - avoidance Rules for Major Developing Countries ISBN 9789041158390
Published October 2014
Kluwer Law International
£154.00
Proportionality and Fair Taxation ISBN 9789041158383
Published October 2014
Kluwer Law International
£167.00
Legal Interpretation of Tax Law ISBN 9789041149459
Published September 2014
Kluwer Law International
Out of print
Tax Reform in the 21st Century: A Volume in Memory of Richard Musgrave ISBN 9789041128294
Published July 2009
Kluwer Law International
£125.00
Interpretation Double Taxation Conventions: General Theory and Brazilian Perspective ISBN 9789041128225
Published February 2009
Kluwer Law International
£173.00
Sales Taxation ISBN 9789065443816
Published January 2002
Kluwer Law International
£212.00
Taxation of Foreign Direct Investment ISBN 9789041197412
Published August 1999
Kluwer Law International
£183.00
The Impact of State Sovereignty on Global Trade and International Taxation ISBN 9789041197030
Published May 1999
Kluwer Law International
£177.00
Multilateral Tax Treaties ISBN 9789041107046
Published June 1998
Kluwer Law International
£220.00
The Improper Use of Tax Treaties ISBN 9789041107374
Published June 1998
Kluwer Law International
£253.00
Taxing Corporate Profits in the EU ISBN 9789041107039
Published September 1997
Kluwer Law International
£279.00
Tax Treatment of Financial Instruments ISBN 9789065446664
Published June 1995
Kluwer Law International
£300.00
Issues in International Partnership ISBN 9789065445773
Published July 1993
Kluwer Law International
£233.00
Permanent Establishment: Erosion of a Tax Treaty Principle ISBN 9789065445940
Published October 1991
Kluwer Law International
Out of print
Tax Treaties and EC Law
ISBN 9789041106803
Published November 1990
Kluwer Law International
£295.00
International Juridical Double Taxation of Income ISBN 9789065444264
Published September 1989
Kluwer Law International
£281.00
Nondiscrimination in International Tax Law ISBN 9789065442666
Published July 1988
Kluwer Law International
£273.00
Tax Co-ordination in the European Community
ISBN 9789065442727
Published March 1987
Kluwer Law International
£388.00
International Studies in Taxation
ISBN 9789041196927
Published December 1968
Kluwer Law International
£253.00
Towards Corporate Tax Harmonization in the European Community
Adolfo J. Martin JimenezAssociate Professorr of Tax Law, University of Cadiz Law School, Jerez de la Frontera, Spain
ISBN 9789041196903
Published December 1968
Kluwer Law International
£296.00