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An Empirical Investigation into the Design of an EU Apportionment Formula Related to Profit Generating Factors

Author

Listed:
  • A. ROGGEMAN
  • I. VERLEYEN
  • P. VAN CAUWENBERGE
  • C. COPPENS

Abstract

The European Commission (EC) has the intention to establish a Common Consolidated Corporate Tax Base, which requires an allocation formula to fairly distribute the consolidated tax base among all group entities. A fair distribution would mean that the allocation is closely related to the profit generating factors of the underlying entities. The EC supposes that fixed tangible assets, sales and labour are the dominant factors in the generation of profit. This paper analyses the profit generating capacity of these factors and of the alternative factor intangible assets. The results show that the proposed factors only explain 28% of the variation in profit. Moreover, the results indicate that recognized intangibles do not increase R2 significantly. However, for R&D intensive companies, adding the market less book value to proxy for unrecognized intangibles, increases the explanatory power with 30%. This suggests that for these companies unrecognized intangibles could be important in generating profit.

Suggested Citation

  • A. Roggeman & I. Verleyen & P. Van Cauwenberge & C. Coppens, 2012. "An Empirical Investigation into the Design of an EU Apportionment Formula Related to Profit Generating Factors," Working Papers of Faculty of Economics and Business Administration, Ghent University, Belgium 12/813, Ghent University, Faculty of Economics and Business Administration.
    • Handle: RePEc:rug:rugwps:12/813
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    File URL: http://wps-feb.ugent.be/Papers/wp_12_813.pdf
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    Citations

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    Cited by:

    1. Veronika Solilová & Danuše Nerudová, 2018. "Výnosový potenciál společného konsolidovaného korporátního základu daně v Evropské unii [Revenue Potential of the CCCTB in the European Union]," Politická ekonomie, Prague University of Economics and Business, vol. 2018(1), pages 78-98.
    2. Ludmila P. Korolyova, 2015. "The role of consolidated groups of taxpayers in providing innovative breakthrough: to be or not to be," Journal of Tax Reform, Graduate School of Economics and Management, Ural Federal University, vol. 1(2-3), pages 177-193.
    3. 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.
    4. 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.
    5. Danuše Nerudová & Veronika Solilová & Hana Bohušová & Patrik Svoboda & Marek Litzman, 2017. "Panelový regresní model: nástroj pro odhad obvyklé rentability tržeb pro účely převodních cen v kontextu malých a středních podniků [Panel Regression Model: A Tool for the Estimation of the Arm´s L," Politická ekonomie, Prague University of Economics and Business, vol. 2017(4), pages 440-459.
    6. Kateřina Krchnivá & Danuše Nerudová, 2015. "The Influence of Allocation Formula on Generation of Profit in Different Economy Sectors," Acta Universitatis Agriculturae et Silviculturae Mendelianae Brunensis, Mendel University Press, vol. 63(6), pages 1961-1967.

    More about this item

    Keywords

    CCCTB; apportionment formula; fairness; international corporate taxation; European Union;
    All these keywords.

    JEL classification:

    • D63 - Microeconomics - - Welfare Economics - - - Equity, Justice, Inequality, and Other Normative Criteria and Measurement
    • F23 - International Economics - - International Factor Movements and International Business - - - Multinational Firms; International Business
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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