The European Commission recently presented a strategy for EU company tax policy that would allow companies to use one set of tax rules to consolidate their EU activities. This consolidated EU tax base would be apportioned to Member States for taxation at local rates. Many EU companies support...

This paper demonstrates that under conditions of imperfect (oligopolistic) competition, a transition from separate accounting (SA) to formula apportionment (FA) does not eliminate the problem of profit shifting via transfer pricing. In particular, if affiliates of a multinational firm face...