IDEAS home Printed from https://ideas.repec.org/a/ucp/nattax/doi10.1086-714112.html
   My bibliography  Save this article

An Assessment of Global Formula Apportionment

Author

Listed:
  • Ruud De Mooij
  • Li Liu
  • Dinar Prihardini

Abstract

Global formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention in recent debates on the future of the international tax framework. This paper exploits different data sets to assess the direct revenue implications of formula apportionment, both globally and for individual countries, under alternative formulas. The aggregate tax base is estimated to fall by approximately 10 percent due to cross-border loss consolidation. The associated loss in global corporate income tax revenue is smaller, though, between 5 and 8 percent depending on the formula, as profit shifting is mitigated. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in low-tax jurisdictions and investment hubs (i.e., countries with a disproportionate ratio of foreign direct investment to gross domestic product), while several large advanced countries are likely to gain. Developing countries most likely gain if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination. The paper also reviews the literature on dynamic effects of formula apportionment, which may significantly alter the results based on static analysis.

Suggested Citation

  • Ruud De Mooij & Li Liu & Dinar Prihardini, 2021. "An Assessment of Global Formula Apportionment," National Tax Journal, University of Chicago Press, vol. 74(2), pages 431-465.
  • Handle: RePEc:ucp:nattax:doi:10.1086/714112
    DOI: 10.1086/714112
    as

    Download full text from publisher

    File URL: http://dx.doi.org/10.1086/714112
    Download Restriction: Access to the online full text or PDF requires a subscription.

    File URL: http://dx.doi.org/10.1086/714112
    Download Restriction: Access to the online full text or PDF requires a subscription.

    File URL: https://libkey.io/10.1086/714112?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    As the access to this document is restricted, you may want to look for a different version below or search for a different version of it.

    Other versions of this item:

    References listed on IDEAS

    as
    1. Edmiston, Kelly D., 2002. "Strategic Apportionment of the State Corporate Income Tax: An Applied General Equilibrium Analysis," National Tax Journal, National Tax Association, vol. 55(N. 2), pages 239-262, June.
    2. Hines Jr., James R., 2010. "Income misattribution under formula apportionment," European Economic Review, Elsevier, vol. 54(1), pages 108-120, January.
    3. 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, August.
    4. 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.
    5. Altshuler, Rosanne & Grubert, Harry, 2010. "Formula Apportionment: Is It Better Than the Current System and Are There Better Alternatives?," National Tax Journal, National Tax Association;National Tax Journal, vol. 63(4), pages 1145-1184, December.
    6. Nadine Riedel, 2010. "The downside of formula apportionment: evidence on factor demand distortions," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 17(3), pages 236-258, June.
    7. Walter Hellerstein & Charles E. McLure, Jr., 2004. "The European Commission's Report on Company Income Taxation: What the EU Can Learn from the Experience of the US States," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 11(2), pages 199-220, March.
    8. Søren Bo Nielsen & Pascalis Raimondos–Møller & Guttorm Schjelderup, 2003. "Formula Apportionment and Transfer Pricing under Oligopolistic Competition," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 5(2), pages 419-437, April.
    9. Leon Bettendorf & Michael P. Devereux & Albert Van Der Horst & Simon Loretz & Ruud A. de Mooij, 2010. "Corporate tax harmonization in the EU [Taxing corporate income]," Economic Policy, CEPR, CESifo, Sciences Po;CES;MSH, vol. 25(63), pages 537-590.
    10. Goolsbee, Austan & Maydew, Edward L., 2000. "Coveting thy neighbor's manufacturing: the dilemma of state income apportionment," Journal of Public Economics, Elsevier, vol. 75(1), pages 125-143, January.
    11. 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;International Institute of Public Finance, vol. 5(1), pages 41-59, February.
    12. Mardan, Mohammed & Stimmelmayr, Michael, 2018. "Tax revenue losses through cross-border loss offset: An insurmountable hurdle for formula apportionment?," European Economic Review, Elsevier, vol. 102(C), pages 188-210.
    13. 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.
    14. Nielsen, Søren Bo & Raimondos-Møller, Pascalis & Schjelderup, Guttorm, 2010. "Company taxation and tax spillovers: Separate accounting versus formula apportionment," European Economic Review, Elsevier, vol. 54(1), pages 121-132, January.
    15. 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.
    16. Buettner, Thiess & Riedel, Nadine & Runkel, Marco, 2011. "Strategic Consolidation Under Formula Apportionment," National Tax Journal, National Tax Association;National Tax Journal, vol. 64(2), pages 225-254, June.
    17. 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;International Institute of Public Finance, vol. 14(5), pages 605-626, October.
    18. Gresik, Thomas A., 2010. "Formula apportionment vs. separate accounting: A private information perspective," European Economic Review, Elsevier, vol. 54(1), pages 133-149, January.
    19. Charles E. McLure, Jr., 1981. "The Elusive Incidence of the Corporate Income Tax: The State Case," NBER Working Papers 0616, National Bureau of Economic Research, Inc.
    20. Tommaso Faccio & Valpy Fitzgerald, . "Sharing the corporate tax base: equitable taxing of multinationals and the choice of formulary apportionment," UNCTAD Transnational Corporations Journal, United Nations Conference on Trade and Development.
    21. Mintz, Jack & Smart, Michael, 2004. "Income shifting, investment, and tax competition: theory and evidence from provincial taxation in Canada," Journal of Public Economics, Elsevier, vol. 88(6), pages 1149-1168, June.
    22. repec:idq:ictduk:11176 is not listed on IDEAS
    23. Wolfgang Eggert & Guttorm Schjelderup, 2003. "Symmetric Tax Competition under Formula Apportionment," Journal of Public Economic Theory, Association for Public Economic Theory, vol. 5(2), pages 439-446, April.
    24. Johannes Becker & Clemens Fuest, 2010. "Tax enforcement and tax havens under formula apportionment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 17(3), pages 217-235, June.
    25. Anand, Bharat N. & Sansing, Richard, 2000. "The Weighting Game: Formula Apportionment as an Instrument of Public Policy," National Tax Journal, National Tax Association;National Tax Journal, vol. 53(2), pages 183-200, June.
    26. Thomas Eichner & Marco Runkel, 2008. "Why the European Union Should Adopt Formula Apportionment with a Sales Factor," Scandinavian Journal of Economics, Wiley Blackwell, vol. 110(3), pages 567-589, September.
    27. Edmiston, Kelly D., 2002. "Strategic Apportionment of the State Corporate Income Tax: An Applied General Equilibrium Analysis," National Tax Journal, National Tax Association;National Tax Journal, vol. 55(2), pages 239-262, June.
    28. Clausing, Kimberly A. & Lahav, Yaron, 2011. "Corporate tax payments under formulary apportionment: Evidence from the financial reports of 50 major U.S. multinational firms," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 20(2), pages 97-105.
    Full references (including those not matched with items on IDEAS)

    Citations

    Citations are extracted by the CitEc Project, subscribe to its RSS feed for this item.
    as


    Cited by:

    1. Javier Garcia-Bernardo & Petr Janský & Thomas Tørsløv, 2021. "Multinational corporations and tax havens: evidence from country-by-country reporting," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 28(6), pages 1519-1561, December.
    2. Javier Garcia-Bernardo & Petr Janský & Thomas Tørsløv, 2022. "Decomposing Multinational Corporations’ Declining Effective Tax Rates," IMF Economic Review, Palgrave Macmillan;International Monetary Fund, vol. 70(2), pages 338-381, June.
    3. Garcia-Bernardo, Javier & Janský, Petr, 2024. "Profit shifting of multinational corporations worldwide," World Development, Elsevier, vol. 177(C).
    4. Sebastian Beer & Ruud de Mooij & Shafik Hebous & Michael Keen & Li Liu, 2023. "Exploring Residual Profit Allocation," American Economic Journal: Economic Policy, American Economic Association, vol. 15(1), pages 70-109, February.
    5. Rosella Levaggi & Carmen Marchiori & Paolo M. Panteghini, 2022. "Lifestyle taxes in the presence of profit shifting," Journal of Economics, Springer, vol. 137(1), pages 81-96, September.
    6. Wolfram F. Richter, 2022. "Granting Market Countries the Right to Tax Profit without Physical Nexus," CESifo Working Paper Series 9556, CESifo.
    7. Kempkes, Gerhard & Stähler, Nikolai, 2021. "Re-allocating taxing rights and minimum tax rates in international profit taxation," Discussion Papers 03/2021, Deutsche Bundesbank.
    8. Małecka-Ziembińska Edyta & Siwiec Anna, 2020. "Searching for similarities in EU corporate income taxes for their harmonization," Economics and Business Review, Sciendo, vol. 6(4), pages 72-94, December.

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Martini, Jan-Thomas & Niemann, Rainer & Simons, Dirk, 2014. "Management incentives under formula apportionment: Tax-induced distortions of effort and compensation in a principal-agent setting," arqus Discussion Papers in Quantitative Tax Research 168, arqus - Arbeitskreis Quantitative Steuerlehre.
    2. Jan Thomas Martini & Rainer Niemann & Dirk Simons, 2014. "Management Incentives under Formula Apportionment - Tax-Induced Distortions of Effort and Compensation in a Principal-Agent Setting -," CESifo Working Paper Series 4908, CESifo.
    3. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2015. "Formula apportionment: Factor allocation and tax avoidance," Discussion Papers 2015/30, Free University Berlin, School of Business & Economics.
    4. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2015. "Formula apportionment: Factor allocation and tax avoidance," arqus Discussion Papers in Quantitative Tax Research 199, arqus - Arbeitskreis Quantitative Steuerlehre.
    5. Martini, Jan Thomas & Niemann, Rainer & Simons, Dirk, 2016. "Tax-induced distortions of effort and compensation in a principal-agent setting," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 27(C), pages 26-39.
    6. Dirk Kiesewetter & Tobias Steigenberger & Matthias Stier, 2018. "Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation, intragroup debt, and leases," Journal of Business Economics, Springer, vol. 88(9), pages 1029-1060, December.
    7. Jochen Hundsdoerfer & Julia Wagner, 2020. "How accurately does the CCCTB apportionment formula allocate profits? An evaluation of the European Commission proposal," Journal of Business Economics, Springer, vol. 90(4), pages 495-536, May.
    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.
    9. Dietrich, Maik, 2009. "Entscheidungswirkungen einer europaweit harmonisierten Konzernbesteuerung [Impacts of European Group Taxation]," MPRA Paper 59870, University Library of Munich, Germany.
    10. Mardan, Mohammed & Stimmelmayr, Michael, 2018. "Tax revenue losses through cross-border loss offset: An insurmountable hurdle for formula apportionment?," European Economic Review, Elsevier, vol. 102(C), pages 188-210.
    11. Hines Jr., James R., 2010. "Income misattribution under formula apportionment," European Economic Review, Elsevier, vol. 54(1), pages 108-120, January.
    12. Eichfelder, Sebastian & Hechtner, Frank & Hundsdoerfer, Jochen, 2017. "Formula apportionment: Factor allocation and tax avoidance," arqus Discussion Papers in Quantitative Tax Research 220, arqus - Arbeitskreis Quantitative Steuerlehre, revised 2017.
    13. Becker, Johannes & Runkel, Marco, 2013. "Corporate tax regime and international allocation of ownership," Regional Science and Urban Economics, Elsevier, vol. 43(1), pages 8-15.
    14. Buettner, Thiess & Riedel, Nadine & Runkel, Marco, 2011. "Strategic Consolidation Under Formula Apportionment," National Tax Journal, National Tax Association;National Tax Journal, vol. 64(2), pages 225-254, June.
    15. Marcel Gérard, 2005. "Multijurisdictional Firms and Governments’ Strategies under Alternative Tax Designs," CESifo Working Paper Series 1527, CESifo.
    16. Sara L. McGaughey & Pascalis Raimondos, 2019. "Shifting MNE taxation from national to global profits: A radical reform long overdue," Journal of International Business Studies, Palgrave Macmillan;Academy of International Business, vol. 50(9), pages 1668-1683, December.
    17. Danuse NERUDOVA & Katerina KRCHNIVA, 2016. "Tax sharing under the Common Consolidated Corporate Tax Base: Measurement of the profit generating factors in the agriculture sector," Agricultural Economics, Czech Academy of Agricultural Sciences, vol. 62(8), pages 363-377.
    18. Fatih Guvenen & Raymond J. Mataloni Jr. & Dylan G. Rassier & Kim J. Ruhl, 2022. "Offshore Profit Shifting and Aggregate Measurement: Balance of Payments, Foreign Investment, Productivity, and the Labor Share," American Economic Review, American Economic Association, vol. 112(6), pages 1848-1884, June.
    19. Regina Ortmann & Caren Sureth-Sloane, 2016. "Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?," Journal of Business Economics, Springer, vol. 86(5), pages 441-475, July.
    20. Rüdiger Pethig & Andreas Wagener, 2007. "Profit tax competition and formula apportionment," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 14(6), pages 631-655, December.

    More about this item

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:ucp:nattax:doi:10.1086/714112. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Journals Division (email available below). General contact details of provider: https://www.journals.uchicago.edu/NTJ .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.