Formulary Apportionment and Group Taxation in the European Union: Insights from the United States and Canada
AbstractIn 2001, the European Commission endorsed a future company tax strategy that would allow EU companies the option of calculating their EU profits on a common consolidated tax base and allow Member States to tax their share of that base at national rates. Implementing this strategy requires developing a formula to distribute the common tax base across the Member States. Although EU Member States currently do not use formulary methods to distribute a common consolidate tax base across national boundaries, Canada and the United States have extensive experience using formulary methods to distribute income across sub-national boundaries. Thus, the European Union can turn to North America to gain valuable insights into the design of a formulary apportionment system with common base taxation. This paper evaluates key issues that may arise when implementing common consolidated base taxation with formulary apportionment in the EU. These issues include the formula design, the definition of the company group and the definition and scope of the tax base. The paper also discusses potential economic consequences that may arise and suggests a potential apportionment system for the European Union.
Download InfoIf you experience problems downloading a file, check if you have the proper application to view it first. In case of further problems read the IDEAS help page. Note that these files are not on the IDEAS site. Please be patient as the files may be large.
Bibliographic InfoPaper provided by Directorate General Taxation and Customs Union, European Commission in its series Taxation Papers with number 8.
Length: 68 pages
Date of creation: Mar 2005
Date of revision: Mar 2005
European Union; Corporate Taxation; Formulary apportionment; common consolidated base taxation; EU company tax reform;
Find related papers by JEL classification:
- F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
- H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
- H73 - Public Economics - - State and Local Government; Intergovernmental Relations - - - Interjurisdictional Differentials and Their Effects
- H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods
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.:
- Mintz, Jack & Weiner, Joann Martens, 2003. "Exploring Formula Allocation for the European Union," International Tax and Public Finance, Springer, vol. 10(6), pages 695-711, November.
- Daly, Michael & Weiner, Joann M., 1993. "Corporate Tax Harmonization and Competition in Federal Countries: Some Lessons for the European Community?," National Tax Journal, National Tax Association, vol. 46(4), pages 441-61, December .
- Rüdiger Pethig & Andreas Wagener, 2003.
"Profit Tax Competition and Formula Apportionment,"
CESifo Working Paper Series
1011, CESifo Group Munich.
- 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.
- Nielsen, Soren Bo & Raimondos-Møller, Pascalis & Schjelderup, Guttorm, 2001. "Tax Spillovers under Separate accounting and Formula Apportionment," CEPR Discussion Papers 2831, C.E.P.R. Discussion Papers.
- Peter SÃ¸rensen, 2004. "Company Tax Reform in the European Union," International Tax and Public Finance, Springer, vol. 11(1), pages 91-115, January.
- Gupta, Sanjay & Mills, Lillian F., 2003. "Does Disconformity in State Corporate Income Tax Systems affect Compliance Cost Burdens?," National Tax Journal, National Tax Association, vol. 56(2), pages 355-71, June Cita.
- Marcel Gérard & Joann Weiner, 2003. "Cross-Border Loss Offset and Formulary Apportionment: How do they affect multijurisdictional firm investment spending and interjurisdictional tax competition ?," CESifo Working Paper Series 1004, CESifo Group Munich.
- Fox, William F. & Luna, LeAnn, 2002. "State Corporate Tax Revenue Trends: Causes and Possible Solutions," National Tax Journal, National Tax Association, vol. 55(3), pages 491-508, September.
- McLure, Charles E. Jr., 2000. "Implementing State Corporate Income Taxes in the Digital Age," National Tax Journal, National Tax Association, vol. 53(n.4), pages 1287-1305, December .
- 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.
- Charles McLure Jr. & Walter Hellerstein, 2002. "Does sales-only apportionment of corporate income violate international trade rules?," CESifo Forum, Ifo Institute for Economic Research at the University of Munich, vol. 3(4), pages 23-30, 03.
- 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.
- Anand, Bharat N. & Sansing, Richard, 2000. "The Weighting Game: Formula Apportionment as an Instrument of Public Policy," National Tax Journal, National Tax Association, vol. 53(n. 2), pages 183-200, June Cita.
- Marcel G�rard, 2006.
"Reforming the taxation of multijurisdictional enterprises in Europe: a tentative appraisal,"
European Economy - Economic Papers
265, Directorate General Economic and Monetary Affairs (DG ECFIN), European Commission.
- Marcel Gérard, 2006. "Reforming the Taxation of Multijurisdictional Enterprises in Europe, a Tentative Appraisal," CESifo Working Paper Series 1795, CESifo Group Munich.
- 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.
- Clemens Fuest & Thomas Hemmegarn & 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 627-629, October.
- Michael Keen & Kai A. Konrad, 2012. "International Tax Competition and Coordination," Working Papers international_tax_competi, Max Planck Institute for Tax Law and Public Finance.
- Marcel Gérard, 2006.
"Reforming the Taxation of Multijurisdictional Enterprises in Europe, “Coopetition” in a Bottom-up Federation,"
CESifo Working Paper Series
1860, CESifo Group Munich.
- Marcel Gerard, 2006. "Reforming the taxation of Multijurisdictional Enterprises in Europe, "Coopetition" in a Bottom-up Federation," Working Papers 2006-10, University of Kentucky, Institute for Federalism and Intergovernmental Relations.
- Marco Runkel & Guttorm Schjelderup, 2007.
"The Choice of Apportionment Factors under Formula Apportionment,"
CESifo Working Paper Series
2072, CESifo Group Munich.
- Marco Runkel & Guttorm Schjelderup, 2011. "The Choice Of Apportionment Factors Under Formula Apportionment," International Economic Review, Department of Economics, University of Pennsylvania and Osaka University Institute of Social and Economic Research Association, vol. 52(3), pages 913-934, 08.
- 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.
For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: (Gaetan Nicodeme) or (Freddy De Buysscher) or (Thomas hemmelgarn).
If references are entirely missing, you can add them using this form.