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The Delineation and Apportionment of an EU Consolidated Tax Base for Multi-jurisdictional Corporate Income Taxation: a Review of Issues and Options

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  • Ana Agundez-Garcia

    (European Commission)

Abstract

The Commission Services study on Company Taxation in the Internal Market and the Communications COM(2001)582 and COM(2003)726 on EU company taxation presented a long-term strategy to tackle the corporate income tax obstacles in the Internal Market by providing multi-jurisdictional companies with a consolidated tax base for their EU-wide activities for corporate taxation purposes. This comprehensive approach relies on a number of crucial steps such as delineating the CTB and choosing the mechanism for apportioning the multinationals' tax bases between the relevant Member States, so that they can then apply the national corporation tax rate to their respective shares. This work systematically addresses some of the fundamental questions that arise when considering the design of a consolidation + apportionment system for sharing multinationals' consolidated profits between EU Member States.

Suggested Citation

  • 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.
    • Handle: RePEc:tax:taxpap:0009
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    Cited by:

    1. Lourdes Jerez Barroso, 2011. "Base imponible y neutralidad del Impuesto de Sociedades: alternativas y experiencias," Hacienda Pública Española / Review of Public Economics, IEF, vol. 197(2), pages 113-146, June.
    2. Annelies Roggeman & Isabelle Verleyen & Philippe Van Cauwenberge & Carine Coppens, 2013. "The EU apportionment formula: insights from a business case," Journal of Business Economics and Management, Taylor & Francis Journals, vol. 14(2), pages 235-251, April.
    3. repec:prg:jnlpep:v:preprint:id:660:p:1-22 is not listed on IDEAS
    4. Paolo Acciari & Francesca Tomarelli & Laura Limosani & Laura Benedetti, 2015. "Measurement of base erosion and profit shifting phenomena through the analysis of FDI stocks," Working Papers 3, Department of the Treasury, Ministry of the Economy and of Finance.
    5. Kateřina Krchnivá & Danuše Nerudová, 2018. "The CCCTB Allocation Formula Game: The Performance of Economics Sectors," Prague Economic Papers, Prague University of Economics and Business, vol. 2018(4), pages 427-448.
    6. Clemens Fuest, 2008. "The European Commission's proposal for a common consolidated corporate tax base," Oxford Review of Economic Policy, Oxford University Press and Oxford Review of Economic Policy Limited, vol. 24(4), pages 720-739, winter.
    7. Michael P Devereux & Simon Loretz, 2008. "Increased efficiency through consolidation and formula apportionment in the European Union?," Working Papers 0812, Oxford University Centre for Business Taxation.

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    More about this item

    Keywords

    European Union; Corporate Taxation; multinational taxation; formula apportionment;
    All these keywords.

    JEL classification:

    • H2 - Public Economics - - Taxation, Subsidies, and Revenue
    • H3 - Public Economics - - Fiscal Policies and Behavior of Economic Agents
    • H87 - Public Economics - - Miscellaneous Issues - - - International Fiscal Issues; International Public Goods

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