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Formula Apportionment in the European Union: A Dream Come True or the EU’s Worst Nightmare?

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  • Joann Weiner

Abstract

The European Commission recently endorsed a future company tax policy that would allow companies to consolidate their tax bases and apportion the income across the EU using an allocation mechanism. This policy would replace the separate accounting method with formula apportionment of EU group profits as the main method of taxing multinational companies in the European Union. However, many details of the approaches remain to be presented, and these details may turn what appears to be a simple solution into an extremely complex one. This paper explores some technical details that arise in adopting formula apportionment in the European Union.

Suggested Citation

  • Joann Weiner, 2002. "Formula Apportionment in the European Union: A Dream Come True or the EU’s Worst Nightmare?," CESifo Working Paper Series 667, CESifo.
    • Handle: RePEc:ces:ceswps:_667
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    References listed on IDEAS

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    1. Joeri Gorter & Ruud de Mooij, 2001. "Capital income taxation in Europe; trends and trade-offs," CPB Special Publication 30, CPB Netherlands Bureau for Economic Policy Analysis.
    2. Søren Bo Nielsen & Pascalis Raimondos-Møller & Guttorm Schjelderup, "undated". "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.
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    4. Mintz, Jack & Weiner, Joann Martens, 2003. "Exploring Formula Allocation for the European Union," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 10(6), pages 695-711, November.
    5. European Commission, 2001. "Company Taxation in the Internal Market," Taxation Studies 0005, Directorate General Taxation and Customs Union, European Commission.
    6. Joeri Gorter & Ruud de Mooij, 2001. "Capital income taxation in Europe; trends and trade-offs," CPB Special Publication 30.rdf, CPB Netherlands Bureau for Economic Policy Analysis.
    7. 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.
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    Cited by:

    1. Gaëtan Nicodème, 2006. "Corporate tax competition and coordination in the European Union: What do we know? Where do we stand?," European Economy - Economic Papers 2008 - 2015 250, Directorate General Economic and Financial Affairs (DG ECFIN), European Commission.
    2. Albert van der Horst & Leon Bettendorf & Hugo Rojas-Romagosa, 2007. "Will corporate tax consolidation improve efficiency in the EU?," CPB Document 141, CPB Netherlands Bureau for Economic Policy Analysis.
    3. Michael P. Devereux & Simon Loretz, 2008. "The Effects of EU Formula Apportionment on Corporate Tax Revenues," Fiscal Studies, Institute for Fiscal Studies, vol. 29(1), pages 1-33, March.
    4. Peter Birch Sørensen, 2003. "Company Tax Reform in the European Union," EPRU Working Paper Series 03-08, Economic Policy Research Unit (EPRU), University of Copenhagen. Department of Economics.
    5. Marcel Gérard & Joann Martens Weiner, 2006. "Comment la compensation internationale des pertes et la répartition proportionnelle des revenus imposables peuvent affecter les choix des multinationales et la concurrence fiscale," Economie & Prévision, La Documentation Française, vol. 0(2), pages 65-77.
    6. 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.
    7. Clemens Fuest & Bernd Huber, 2003. "Zur Koordinierung der Unternehmensbesteuerung in Europa," Vierteljahrshefte zur Wirtschaftsforschung / Quarterly Journal of Economic Research, DIW Berlin, German Institute for Economic Research, vol. 72(3), pages 378-390.
    8. Dietrich, Maik, 2009. "Entscheidungswirkungen einer europaweit harmonisierten Konzernbesteuerung [Impacts of European Group Taxation]," MPRA Paper 59870, University Library of Munich, Germany.
    9. 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.
    10. Marcel Gérard, 2006. "Reforming the Taxation of Multijurisdictional Enterprises in Europe, “Coopetition” in a Bottom-up Federation," CESifo Working Paper Series 1860, CESifo.
    11. 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.
    12. 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 2020, CESifo.
    13. Marcel Gérard, 2005. "Multijurisdictional Firms and Governments’ Strategies under Alternative Tax Designs," CESifo Working Paper Series 1527, CESifo.
    14. Peter Sørensen, 2004. "Company Tax Reform in the European Union," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 11(1), pages 91-115, January.

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