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-border loss offset inherent to formula apportionment. In the medium run, in which only firms can adjust their strategies, tax …, contrary to output factors, input factors provide an insurance against tax revenue shortfalls due to loss-making affiliates. …
Persistent link: https://www.econbiz.de/10011611957
This paper analyzes the effect on firm behavior and national tax revenues of a policy of allowing multinational firms to choose whether to be taxed under separate accounting rules (transfer prices) or an apportionment formula. Either method can be preferred by low-cost firms and by high-cost...
Persistent link: https://www.econbiz.de/10010227185
European Tax Allocation System (ETAS). In a dynamic capital budgeting model we analyze the impacts of selected loss … that replacing Separate Accounting by either concept can lead to increasing profitability due to cross-border loss … occur in favor of the holding. National loss-offset limitations and minimum taxation concepts in tendency lose their impact …
Persistent link: https://www.econbiz.de/10013102071
Das Nebeneinander der 27 europäischen Steuersysteme verzerrt Standort-, Investitions- und Finanzierungsentscheidungen und behindert die grenzüberschreitende Geschäftstätigkeit von Unternehmen im Binnenmarkt. Diese Hindernisse beabsichtigt die Europäische Union durch die Einführung der...
Persistent link: https://www.econbiz.de/10011942824
Persistent link: https://www.econbiz.de/10011492031
In order to calculate the burden of a comprehensive and progressive income tax falling on a certain income source, an apportionment scheme for the entire tax burden has to be chosen. This raises the question of how to deal with losses, which is relevant for Germany in view of the heavy losses...
Persistent link: https://www.econbiz.de/10003902662
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...
Persistent link: https://www.econbiz.de/10012859856
Formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention. This paper reviews existing literature and discusses experiences in selective federal states to evaluate the economic properties of formula apportionment relative...
Persistent link: https://www.econbiz.de/10012112121
According to plans put forward by the OECD/G20 Inclusive Framework on BEPS, a share of residual profit earned by eligible MNEs is to be taxed by market jurisdictions. For this purpose, revenue-based formulaic apportionment of residual profit is proposed. This note argues against the use of a...
Persistent link: https://www.econbiz.de/10012595108