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Following a new tax leader: the urge to implement Formulary Apportionment in the European Union

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  • Joana Andrade Vicente

Abstract

In this paper we analyse the United States’ role as the current international tax leader, acting as an institutional leader uncapable of pushing forward towards a new, more suitable international corporate tax regime, due to the particularities of its international taxation system and economic preferences. After assessing United States multinationals’ activity in the Single Market, we find evidence of artificial profit shifting across Member States under the current method to allocate multinational enterprises’ profits. Such actions challenge a fair international taxation in the European Union, distorting European internal competition and hampering tax revenues collection. Although it may not be (yet) the time for a worldwide unitary taxation approach, the analysis performed highlights the urge for the European Union to overcome the United States political power and to unilaterally adopt the Formulary Apportionment approach, overhauling a century-old set of global tax rules based in the separate entity approach.

Suggested Citation

  • Joana Andrade Vicente, 2023. "Following a new tax leader: the urge to implement Formulary Apportionment in the European Union," Working Papers REM 2023/0274, ISEG - Lisbon School of Economics and Management, REM, Universidade de Lisboa.
    • Handle: RePEc:ise:remwps:wp02742023
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    File URL: https://rem.rc.iseg.ulisboa.pt/wps/pdf/REM_WP_0274_2023.pdf
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    References listed on IDEAS

    as
    1. Menkhoff, Lukas & Miethe, Jakob, 2019. "Tax evasion in new disguise? Examining tax havens' international bank deposits," Journal of Public Economics, Elsevier, vol. 176(C), pages 53-78.
    2. Dharmapala, Dhammika & Riedel, Nadine, 2013. "Earnings shocks and tax-motivated income-shifting: Evidence from European multinationals," Journal of Public Economics, Elsevier, vol. 97(C), pages 95-107.
    3. Kimberly A. Clausing, 2020. "Profit Shifting before and after the Tax Cuts and Jobs Act," National Tax Journal, National Tax Association;National Tax Journal, vol. 73(4), pages 1233-1266, December.
    4. Menkhoff, Lukas & Miethe, Jakob, 2019. "Tax evasion in new disguise? Examining tax havens' international bank deposits," Journal of Public Economics, Elsevier, vol. 176(C), pages 53-78.
    5. Dharmapala, Dhammika & Hines Jr., James R., 2009. "Which countries become tax havens?," Journal of Public Economics, Elsevier, vol. 93(9-10), pages 1058-1068, October.
    Full references (including those not matched with items on IDEAS)

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    More about this item

    Keywords

    Country-by-Country Reporting; European Union; Formulary Apportionment; United States multinationals enterprises; tax havens.;
    All these keywords.

    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
    • H26 - Public Economics - - Taxation, Subsidies, and Revenue - - - Tax Evasion and Avoidance

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