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

Ana Agúndez-García

54 citations0/0 files storedRePEc: Research Papers in Economics

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Taxation and Legal Issues Corporate Taxation and Avoidance EU Law and Policy Analysis

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.

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1991Taxes, Tariffs and Transfer Pricing in Multinational Corporate Decision Making 2003Income shifting, investment, and tax competition: theory and evidence from provincial taxation in Canada 2002Repatriation taxes, repatriation strategies and multinational financial policy 1990Taxation in the global economy 2003Tax Competition and Tax Coordination in the European Union 2004The European Commission's Report on Company Income Taxation: What the EU Can Learn from the Experience of the US States 2003Cross-Border Loss Offset and Formulary Apportionment: How Do They Affect Multijurisdictional Firm Investment Spending and Interjurisdictional Tax Competition?1981The Elusive Incidence of the Corporate Income Tax: The State Case

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2019Residual Profit Allocation by Income 2007A Proposal to Adopt Formulary Apportionment for Corporate Income Taxation: The Hamilton Project 2010International Tax Coordination for a Second-Best World (Part III)

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