Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms...
Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surpris...
The European Commission presented a strategy that would allow EU companies to compute their EU tax base under a single set of tax rules at the EU level and use a common formula to distribute this tax base across the individual Member States. Company Tax Reform and Formulary Apportionment in the European Union provides broad guidance for the EU in shaping a system of consolidated base taxation with formulary apportionment. It evaluates how the U.S. states and Canadian provinces have resolved the economic, political, and technical aspects of the formulary apportionment method. The book...
The European Commission presented a strategy that would allow EU companies to compute their EU tax base under a single set of tax rules at the EU leve...
