Formulary apportionment in international tax law

Beschreibung

This thesis explores how global profits of multinational enterprises can be fairly taxed in the age of digitalization and globalization. As value creation and the place of taxation increasingly diverge, transfer pricing based on the arm’s length principle reaches its limits. Therefore, the paper analyzes formulary profit apportionment as an alternative method, ultimately assessing it as a pragmatic tool to counter (aggressive) tax planning by global players.
This thesis explores how global profits of multinational enterprises can be fairly taxed in the age of digitalization and globalization. As value creation and the place of taxation increasingly diverge, transfer pricing based on the arm’s length principle reaches its limits. Therefore, the paper analyzes formulary profit apportionment as an alternative method, ultimately assessing it as a pragmatic tool to counter (aggressive) tax planning by global players.

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Michael Mautsch

Themen in »Formulary apportionment in international tax law«

Transfer Pricing Arm’s Length Principle Base Erosion and Profit Shifting (BEPS) Pillar I Value Creation Digital Economy OECD/G20 Common Consolidated Corporate Tax Base (CCCTB) Business in Europe: Framework for Income Taxation (BEFIT)

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