Formulary Apportionment in the EU
European policy makers have considered implementing a common EU tax base which has to be formulary apportioned among the EU Member States. This book develops an apportionment formula that fits best for the EU. For this purpose, existing formulary approaches - from the US, Canada, Switzerland, and Germany - are analyzed in great detail in order to be in a position to pick the best elements of each. In addition, the basic principles of international corporate taxation, an economic analysis, and conceptual issues of formulary apportionment are taken into account. The book is particularly concerned with the question how to make the apportionment scheme best capture the contribution of intangible assets to the creation of taxable profits.
Publication Date: 2/1/2009