Search Results - subject:"Formula Apportionment"

Reallocating taxing rights and online trade : pillar one as a partial formula apportionment

Mukunoki, Hiroshi; Okoshi, Hirofumi; Schindler, Dirk - 2025

Persistent link: https://www.econbiz.de/10015374080

Becker, Johannes - 2024

Many federal tax systems employ formula apportionment to allocate the taxable profits of large businesses to the … this gap, I adopt an axiomatic approach and derive a generalized system of formula apportionment based on three criteria …: fixed coverage, positive responsiveness, and external independence. I demonstrate that any formula apportionment system …

Persistent link: https://www.econbiz.de/10014632348

Splitting of corporate taxes in Germany and formulaic distribution of a CCCTB : critical comparison

Müller-Thomczik, Sandra; Reiter, Lukas - In: Central European economic journal 9 (2022) 56, pp. 269-290

The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting...

Persistent link: https://www.econbiz.de/10013502253

Taxing multinational enterprises : a theory-based approach to reform

Richter, Wolfram F. - 2022

Almost 140 countries have agreed to reallocate the rights to tax international corporate profits and to introduce minimum tax rates. The agreed plan is the product of pragmatism and a search for consensus, but ambitious. It includes steps towards unitary taxation to be established by a...

Persistent link: https://www.econbiz.de/10013463290

Rationalizing Formula Apportionment

Becker, Johannes - 2024

Many federal tax systems employ formula apportionment to allocate the taxable profits of large businesses to the … adopt an axiomatic approach and derive a generalized system of formula apportionment based on three criteria: fixed coverage …, positive responsiveness, and external independence. I demonstrate that any formula apportionment system meeting these three …

Persistent link: https://www.econbiz.de/10015061898

Unveiling the variation in corporate tax base distribution under the formulary apportionment

Mlčúchová, Markéta - In: Danube : law and economics review 15 (2024) 3, pp. 203-220

This paper reflects the tabled novel framework for corporate taxation in the European Union, founded on the Formulary Apportionment methodology and envisaged inclusion of intangible assets in the allocation formula. The objective is to simulate the variation between the currently used Separate...

Persistent link: https://www.econbiz.de/10015190409

Proposal for "Business in Europe: Framework for Income Taxation" (BEFIT) : a wrong turn in the right direction

Michel, Bob; Schultz, Alison; Millán, Lucas - 2024

Persistent link: https://www.econbiz.de/10015192646

Formulary apportionment in BEFIT : a path to fair corporate taxation

Palanský, Miroslav; Schultz, Alison - 2024

Persistent link: https://www.econbiz.de/10015192647

Distortional effects of separate accounting and formula apportionment on factor allocation

Ortmann, Regina; Pummerer, Erich - In: Journal of Business Economics 93 (2023) 8, pp. 1277-1307

We examine distortions caused by tax base allocation systems–separate accounting (SA) or formula apportionment (FA …

Persistent link: https://www.econbiz.de/10015165536

Corporate taxation in the European Union : the role of intangibles in the formulary apportionment

Mlčúchová, Markéta - In: Národohospodářský obzor : časopis věnovaný … 23 (2023) 3, pp. 181-201

This paper seeks to contribute to the current debate on EU-wide corporate taxation, steered by the impending Proposal by the European Commission on a new framework for the taxation of income of businesses in Europe. The objective of this paper is to verify whether the inclusion of intangible...

Persistent link: https://www.econbiz.de/10014480136