Formulary apportionment is an intensively debated mechanism for allocating tax base within multinational groups. Systems under which the formula is identical in all jurisdictions and systems under which jurisdictions can determine the weights on the formula factors individually can be observed....

Formulary apportionment is an intensively debated mechanism for allocating tax base within multinational groups. Systems under which the formula is identical in all jurisdictions and systems under which jurisdictions can determine the weights on the formula factors individually can be observed....

Transfer Pricing policies are the focus of many investigations on corporate income around the world, yet corporations rarely use models and metrics to estimate their exposure to tax risk. In this paper I propose a framework for multinational enterprises to deal with transfer pricing risk, i.e....