This paper analyzes the optimal level of transfer pricing manipulation when the expected tax penalty is a function of the tax enforcement and the market price parameter, and the multinational enterprise is subjected to distinct rules of foreign profit taxation. The application of the arm's...

The European Commission recently endorsed a future company tax policy that would allow companies to consolidate their tax bases and apportion the income across the EU using an allocation mechanism. This policy would replace the separate accounting method with formula apportionment of EU group...

Conducted in a framework which embodies tax-shifting opportunities, risk of losses and possibility of interjurisdictional loss-offset, this paper investigates a reform of multijurisdictional enterprises taxation, a move from Separate Accounting to Formulary Apportionment. Findings are summarised...

This paper proposes an analysis of two major tax events which occurred in the European Union in 2001, the move of Germany from imputation to exemption and the objective announced by the EU Commission to provide EU businesses with a consolidated corporate tax base for their EU-wide activities. In...

Motivated by the EU Commission's suggested company tax reforms, this paper investigates how cross-border loss offset and formulary apportionment of a consolidated tax base affect the investment and transfer pricing behaviour of a multijurisdictional firm, and how they affect the behaviour of...

This article reviews the main technical and policy problems which the implementation of two formats of comprehensive solutions, discussed in the recent report by the Commission on 'Company Taxation in the Internal market' would require. Both approaches imply the consolidation within the EU of...