European Union - The Apportionment Formula under the European Proposal for a Common Consolidated Corporate Tax Base
ISSN: 0014-3138
Year of publication: 2018
Volume: 58
Issue: 6
Pages: 230-236
Type: Article
More publications in: European taxation
Abstract
In this article, the author discusses the sharing mechanism suggested in the Common Consolidated Corporate Tax Base proposal, which employs three equally-weighted factors: assets, labour and sales. The author argues that although there is no doubt that the transfer pricing regime should be replaced by a more effective system, designing an adequate method requires taking into consideration the unique characteristics of the European Union and the experience with formulary apportionment in other states.