The allocation of multinational business income
Subtitle: reassessing the formulary apportionment option
By: edited by Richard Krever and Francois Vaillancourt
Series: Series on international taxation -- volume 76
Publisher: Wolters Kluwer
Published: 2020
Place of publication: Alphen aan den Rijn, The Netherlands
Language: eng
Number of pages: 338
ISBN-13: 9789403506142; 9789403506159; 9789403506203
Subjects: International business enterprises; Taxation; Law and legislation
Description: 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 Although an arm's length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries.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 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.
Notes: Includes bibliographical references and index.

Current Copyright Fee: GBP20.00 0.
Table of contents: title: Introduction: Reassessing the formulary apportionment option / Krever, R.E., Vaillancourt, F.; title: Chapter 1: History and theory of formulary apportionment / Krever, R.E., Mellor, P.; title: Chapter 2: The US States' experience with formulary apportionment / Sicilian, S., Huddleston, J.; title: Chapter 3: Formulary apportionment in Canada and taxation of corporate income in 2019 : current practice, origins and evaluation / Smart, M., Vaillancourt, F.; title: Chapter 4: The dream is alive : EU tax policy with a common consolidated corporate tax base and formulary apportionment / Weiner, J.M.; title: Chapter 5: The application of formulary apportionment to related entities : lessons from the US experience / Hellerstein, W.; title: Chapter 6: Is unilateral formulary apportionment better than the status quo? / Fleming, J.C. (Jr.), Peroni, R.J., Shay, S.E.; title: Chapter 7: A framework for assessing business sector formulary apportionment / Sadiq, K.; title: Chapter 8: Between arm's length and formulary apportionment / Brauner, Y.; title: Chapter 9: Is arm's length profit split methodology morphing into a formulary apportionment hybrid : the Chinese example / Gao, F., Ting, A.; title: Chapter 10: Value creation and the allocation of profits under a formulary apportionment system / Vella, J.; title: Chapter 11: Formulating the international tax debate : where does formulary apportionment fit? / Grinberg, I.; title: Chapter 12: International tax sharing : can the dream become reality? / Bird, R., Mintz, J.M.