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Exploring Formula Allocation for the European Union

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Author Info
Mintz, Jack
Weiner, Joann Martens

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Abstract

This paper explores the efficiency impacts of two methods of consolidated base taxation with formula allocation under consideration in the European Union. The first method, common (consolidated) base taxation (CCBT), would allow companies to choose a single tax base for their EU-wide operations. This tax base would be common throughout the participating member states. The second method, Home State taxation (HST), would also allow companies to choose a single tax base for their EU-wide operations. But, unlike with CCBT, the tax base would be defined according to the rules in the company's residence, or "home," state. Thus, several different tax bases would exist within the EU. Both methods would use a common formula to distribute profits across countries. This paper finds that since countries continue to set corporate income tax rates, economic inefficiencies continue to exist under both methods. However, under HST, since the tax base differs according to residence, additional inefficiencies may arise depending on whether countries reduced their tax rates to combat the incentive for companies to relocate to locations with narrow tax bases. Copyright 2003 by Kluwer Academic Publishers

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Publisher Info
Article provided by Springer in its journal International Tax and Public Finance.

Volume (Year): 10 (2003)
Issue (Month): 6 (November)
Pages: 695-711
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Handle: RePEc:kap:itaxpf:v:10:y:2003:i:6:p:695-711

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Please report citation or reference errors to , or , if you are the registered author of the cited work, log in to your RePEc Author Service profile, click on "citations" and make appropriate adjustments.:
  1. Joeri Gorter & Ruud de Mooij, 2001. "Capital income taxation in Europe: trends and trade offs," CPB Special Publications 30, CPB Netherlands Bureau for Economic Policy Analysis. [Downloadable!]
  2. Douglas Shackelford & Joel Slemrod, 1998. "The Revenue Consequences of Using Formula Apportionment to Calculate U.S. and Foreign-Source Income: A Firm-Level Analysis," International Tax and Public Finance, Springer, vol. 5(1), pages 41-59, February. [Downloadable!] (restricted)
  3. Søren Bo Nielsen & Pascalis Raimondos-Møller & Guttorm Schjelderup, . "Tax Spillovers under Separate Accounting and Formula Apportionment," EPRU Working Paper Series 01-07, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics. [Downloadable!]
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  4. Gordon, Roger H & Wilson, John Douglas, 1986. "An Examination of Multijurisdictional Corporate Income Taxation under Formula Apportionment," Econometrica, Econometric Society, vol. 54(6), pages 1357-73, November. [Downloadable!] (restricted)
  5. Klassen, Kenneth J. & Shackelford, Douglas A., 1998. "State and provincial corporate tax planning: income shifting and sales apportionment factor management," Journal of Accounting and Economics, Elsevier, vol. 25(3), pages 385-406, June. [Downloadable!] (restricted)
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  1. Clemens Fuest & Thomas Hemmelgarn & Fred Ramb, 2007. "How would the introduction of an EU-wide formula apportionment affect the distribution and size of the corporate tax base? An analysis based on German multinationals," International Tax and Public Finance, Springer, vol. 14(5), pages 605-626, October. [Downloadable!] (restricted)
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  2. Michael Devereux, 2004. "Debating Proposed Reforms of the Taxation of Corporate Income in the European Union," Asia-Pacific Financial Markets, Springer, vol. 11(1), pages 71-89, January. [Downloadable!] (restricted)
  3. Ulrich Schreiber & Gregor Führich, 2009. "European group taxation-the role of exit taxes," European Journal of Law and Economics, Springer, vol. 27(3), pages 257-274, June. [Downloadable!] (restricted)
  4. Jan Thomas Martini & Rainer Niemann & Dirk Simons, 2007. "Transfer Pricing or Formula Apportionment? Tax-Induced Distortions of Multinationals’ Investment and Production Decisions," CESifo Working Paper Series CESifo Working Paper No. , CESifo Group Munich. [Downloadable!]
  5. Fuest, Clemens & Hemmelgarn, Thomas & Ramb, Fred, 2006. "How would formula apportionment in the EU affect the distribution and the size of the corporate tax base? An analysis based on German multinationals," Discussion Paper Series 1: Economic Studies 2006,20, Deutsche Bundesbank, Research Centre. [Downloadable!]
  6. Joann Martens Weiner, 2005. "Formulary Apportionment and Group Taxation in the European Union: Insights from the United States and Canada," Taxation Papers 8, Directorate General Taxation and Customs Union, European Commission, revised Mar 2005. [Downloadable!]
  7. Clemens Fuest, 2008. "The European Commission´s Proposal for a Common Consolidated Corporate Tax Base," Working Papers 0823, Oxford University Centre for Business Taxation. [Downloadable!]
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  8. Ana Agundez-Garcia, 2006. "The Delineation and Apportionment of an EU Consolidated Tax Base for Multi-jurisdictional Corporate Income Taxation: a Review of Issues and Options," Taxation Papers 9, Directorate General Taxation and Customs Union, European Commission, revised Oct 2006. [Downloadable!]
  9. Stöwhase, Sven, 2004. "Asymmetric Capital Tax Competition with Profit Shifting," Discussion Papers in Economics 454, University of Munich, Department of Economics. [Downloadable!]
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