formulary apportionment
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The concept formulary apportionment represents the subject, aboutness, idea or notion of resources found in International Bureau of Fiscal Documentation.
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formulary apportionment
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The concept formulary apportionment represents the subject, aboutness, idea or notion of resources found in International Bureau of Fiscal Documentation.
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- formulary apportionment
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- "Taxation where value is created" and the OECD/G20 base erosion and profit shifting initiative
- 'Profits' in profit-split methods : hazardous crossovers on the way to global formulary apportionment
- A major simplification of the OECD's pillar 1 proposal
- A matter of substance
- Aktuelles zum Fremdvergleichsgrundsatz
- Allocation and apportionment : lessons from the U.S. state tax system
- An alternate solution for France's digital services tax
- An exploration of formula apportionment in the European Union
- Analysis of a formulary system for dividing income, part II : examining current formulary and arm's-length approaches
- Analysis of a formulary system for dividing income, part III : comparative assessment of formulary, arm's-length regimes
- Analysis of a formulary system, part IV : choosing a tax base
- Analysis of a formulary system, part V : apportionment using a combined tax base
- Analysis of a formulary system, part VI : building the formula
- Analysis of a formulary system, part VII : the sales factor
- Analysis of a formulary system, part VIII : suggested statutory, regulatory language for implementing formulary apportionment
- Apple and the CCCTB : can the European Commission have both?
- Apportioning interest expense to the US branch of a foreign corporation
- Are the U.N. and OECD walking together into the formulary apportionment abyss?
- Are the worldwide unitary regimes able to address the perceived shortcoming of the international tax framework?
- Arm's length or formulary apportionment? A European Union perspective
- Arm's length or formulary apportionment? Sometimes the best choice is both
- At the crossroads of reform : nexus concept and profit allocation rules in light of Pillar One and the C(C)CTB Proposal - A comparative study
- BEFIT : is the arm's length principle still fit for purpose?
- BEFIT and formulary apportionment : should intangibles be included in the formula?
- BEPS : is the OECD now at the gates of global formulary apportionment?
- BEPS Action 3 missing in action : CFC rules or global formulary apportionment?
- Behind the OECD's attack on global formulary apportionment
- Between extremes : merging the advantages of separate accounting and unitary taxation
- Between formulary apportionment and the OECD Guidelines : a proposal for reconciliation
- CCCTB : selected issues
- Can the income tax be saved? The promise and pitfalls of adopting worldwide formulary apportionment
- Challenging the status quo : the case for combined reporting
- Cognitive capture, parliamentary parentheses, and the rise of fractional apportionment
- Comment on M. Nieminen: "Destination with credit formula : a simple add on that would make the CCCTB more resilient to tax competition and tax planning"
- Comment on M. Nieminen: "Destination with credit formula : a simple add on that would make the CCCTB more resilient to tax competition and tax planning"
- Common Consolidated Corporate Tax Base and Limitation on Benefits Clauses
- Common consolidated corporate tax base
- Common consolidated corporate tax base
- Common consolidated corporate tax base
- Common consolidated corporate tax base (CCCTB)
- Computation of taxable income : attribution of general expenses to permanent establishment
- Contemporary application of the arm's length principle in transfer pricing
- Corporate income taxes under pressure : why reform is needed and how it could be designed
- Corporate tax consolidation and enhanced cooperation in the European Union
- Cost sharing regulations : the case for formulary apportionment transfer pricing
- Country-by country reporting : a path to transparency, or a prelude to a formulary apportionment approach?
- Country-by-country reporting : potential audit and legislative risks for MNEs
- Currency exchange problems in California's worldwide unitary taxation
- De CCCTB - een Europees voorstel met vergaande gevolgen voor Nederland
- De Common Consolidated Corporate Tax Base (CCCTB) : mogelijke elementen van het toerekeningsmechanisme
- De verdeelsleutel van de CCCTB
- Destination-based income taxation : neither principled nor practical?
- Destination-with-credit formula : a simple add-on that would make the CCCTB more resilient in the face of tax competition and tax planning
- Developing country taxation, part IV: BEPS, formulary apportionment and practical steps
- Die Ermittlung der Bemessungsgrundlage von Amount A und die formelhafte Gewinnzuordnung
- Draft rules proposed by India on profit attribution to permanent establishment : an analysis
- EU corporate tax harmonization : road to nowhere?
- EU: a common consolidated tax base - possible elements of the sharing mechanism
- Emerging perspectives on the evolving arm's length principle and formulary apportionment
- Foreign business meet the wild, wild world of SALT - part 2
- Formula apportionment : is it better than the current system and are there better alternatives?
- Formula apportionment or separate accounting? Tax-induced distortions of multinationals' locational investment decisions
- Formula based transfer pricing
- Formula one : the race to find a common formula to apportion the EU tax base
- Formulary apportionment - myths and prospects : promoting better international tax policies by utilizing the misunderstood and under-theorized formulary alternative
- Formulary apportionment : a revamp in the post-base erosion and profit shifting era?
- Formulary apportionment : the case of the missing income
- Formulary apportionment for Europe : an analysis and a proposal
- Formulary apportionment for the Internal Market
- Formulary apportionment in the European Union
- Formulary apportionment is not a panacea : part 1
- Formulary apportionment is not a panacea : part 2
- Formulary apportionment is not a panacea : part 3
- Formulary apportionment is not a panacea : part 4
- Formulary apportionment is not a panacea : part 5
- Formulary apportionment is not a panacea : part 6
- Fundamentals of international transfer pricing in law and economics
- Global enterprise taxation (GET)
- Global tax fairness
- Global tax governance: what is wrong with it and how to fix it
- Going the way of the Polaroid : digital taxation and the end of the arm's-length principle?
- Harry Grubert's evolving views on international tax policy
- How global tax reforms apply to the extractive industries
- How might your business be taxed under current digital tax proposals?
- Impact of cloud computing on permanent establishments under the OECD Model Tax Convention
- Integration approaches to group taxation in the European Internal Market
- International tax coordination for a second-best world (part III)
- International taxation of permanent establishments : principles and policy
- Is big data that simple? An analysis of the transfer pricing aspects of value creation of data in the digitalized economy
- It's past time for formulary apportionment
- Justiça fiscal internacional e tributação de lucros de grupos multinacionais
- Memorandum to the U.S. Congress : you wouldn't like worldwide formula apportionment
- Modelling corporate tax reform in the EU : new calibration and simulations with the CORTAX model
- More open issues regarding the consolidated corporate tax base in the European Union
- Multilateral formulary apportionment model : a reality check
- NAFTA and formulary apportionment : an exploration of the issues
- OECD BEPS project : tax challenges of the digital economy (part 2)
- OECD CbC risk assessment handbook : formulary apportionment is the new arm's length
- Om OECD's BEPS-prosjekt, et feilslatt internasjonalt skattesystem og mangel pa godt alternativ - en kommentar til professor Ole Gjems-Onstad i SR 2016 s. 2
- Opinion statement FC 3/2017 on the proposed directives for the introduction of a common corporate tax base and common consolidated corporate tax base
- People functions redux : a new approach to profit-splitting factors
- People functions redux, part II: value-driven profit apportionment
- Permanent establishment : no deduction of losses of foreign permanent establishment
- Picciotto's dilemma : what is unitary taxation?
- Pillar One and Pillar Two : a confirmation of the formulaic apportionment and anti-avoidance approaches of the value creation functional DEMPE formula standard?
- Proceedings 87th annual conference on taxation : Charleston, S.C., November 13-15, 1994 : and minutes of the annual meeting held Wednesday, November 13, 1994
- Profit allocation within MNEs in light of the ongoing digital debate on Pillar I : a "2020 Compromise"?
- Profit shifting and certainty on allocation of intangibles
- Profit splits post-BEPS : quantifying an MNE's intangibles
- Profit-split methods and the OECD : leaning toward formulary apportionment?
- Progressive formulary apportionment : the case for 'amount D'
- Proposal for an enhanced CCTB as alternative to a CCCTB with formulary apportionment
- Proposal for country-by-country reporting
- Proposed changes to US transfer pricing law
- Reactions to the common consolidated corporate tax base proposals of the European Commission
- Ready for my close-up, Mr. Demille : formulary apportionment's ticket out of Palookaville
- Reflections on the cross-border tax challenges of the digital economy
- Related-party transfers of intangibles : standards and recommendations for combating international transfer pricing abuses
- Replacing separate entity accounting and the arm's length principle with formulary apportionment
- Report on operation of transfer pricing taxation system in Korea
- Residence-based formulary apportionment : (in)feasibility and implications
- Rethinking the interest deduction rules in light of the Chevron Australia case
- Selected issues on interstate apportionment of corporation income in the US : a model for Europe?
- Selectivity in State aid law and the methods for the allocation of the corporate tax base
- Self-help and altruism : exploring the problem of tax base erosion in developing countries
- Sharing the benefits of the EU's common consolidated corporate tax base within corporate groups
- Sharing the pie : taxing multinationals in a global market
- Shay urges action on intangibles, excess return proposals amid U.S. Ways & Means hearing on transfer pricing regime
- Some open negotiation issues involving a common consolidated corporate tax base in the European Union
- Starting the conversation : a formulary system for dividing income among taxing jurisdictions [part I]
- State taxation of foreign dividends after Mobil v. Vermont : adjusting the apportionment formula
- Stateless income's challenge to tax policy, part 2
- Strategic consolidation under formula apportionment
- Supplementing consolidation and apportionment with anti-abuse provisions
- Sustainability of the arm's length principle as the basis for international income allocation in a digitalising economy : recommendations for the Dutch and international legal system based on a multi-jurisdictional legal comparison taking into consideration the OECD/G20 BEPS project
- Taxation and digitalisation of the economy
- Taxation of multinational banks : using formulary apportionment to reflect economic reality (part 1)
- Taxation of multinational banks : using formulary apportionment to reflect economic reality (part 2)
- Taxation under formula apportionment : tax competition, tax incidence, and the choice of apportionment factors
- Taxing global digital commerce
- Taxing multi-nationals under union wage bargaining
- Taxing multinational enterprises as unitary firms
- Taxing multinational entreprises as unitary entities
- The Achilles' heel of the arm's length principle and the Canadian GlaxoSmithKline case
- The CCCTB as a proposed solution to the corporate income taxation dilemma within the EU
- The CCCTB concept of consolidation and the rules on entering a group
- The Dutch view on the common consolidated corporate tax base
- The EU common consolidated corporate tax base
- The European Union and formula apportionment: Caveat Emptor
- The IMF Policy Paper and formulary apportionment : an alternative international tax architecture? Part 1
- The IMF Policy Paper and formulary apportionment : an alternative international tax architecture? Part 2
- The OECD Work Program : Tax Challenges of the Digitalization of the Economy (Part 2)
- The allocation and apportionment of deductions for state income taxes
- The allocation of multinational business income : reassessing the formulary apportionment option
- The apportionment formula under the European proposal for a Common Consolidated Corporate Tax Base
- The arm's-length standard is not the problem
- The attraction and feasibility of formula apportionment for the European Union
- The case for formulary apportionment
- The case for unitary taxation of international enterprises
- The case for unitary taxation with formulary apportionment in the finance sector and the effect on developing nations
- The determination of transfer prices for tax purposes : prepered by Korea. Country Note No. 8
- The effects of EU formula apportionment on corporate tax revenues
- The future of the profit split method
- The greatest impediment to a rational international tax system
- The lessons of stateless income
- The profit split method : historical evolution and BEPS insights [part 1]
- The revenue consequences of EU formula apportionment
- The taxation of business profits under tax treaties
- The taxation of multinational banks : alternative apportionment through a unitary taxation regime aligning with economic reality
- The three-factor formula vs. the sources of income in the new and weightless economy
- The transfer pricing aspects of cross-border performance guarantees
- The transition to unitary taxation
- The unitary method and the myth of arm's length
- The use of combined reporting by Nation-States
- The use of combined reporting by nation states
- The way we were? The way we must be? The arm's length principle sees itself (for what it is) in the 'digital' mirror
- Toward a 21st-century international tax regime
- Transfer pricing and distribution arrangements : from arm's length to formulary apportionments of income
- Transfer pricing regimes for developing countries
- Two answers to the corporate tax quagmire
- U.S. Senate Committee considers proposals to institute formulary apportionment
- U.S. federal use of formula apportionment to tax income from intangibles
- UTPR : unprecedented (and unprincipled?) tax policy response
- Unitary approaches in international taxation
- Unitary taxation - the case for global formulary apportionment
- Unitary taxation with combined reporting: the TP solution?
- United States : unitary taxation
- United States : unitary taxation : a dissenting opinion
- Using NAFTA to introduce formulary apportionment
- Using the experience in the U.S. states to evaluate issues in implementing formula apportionment at the international level
- Using the experience in the U.S. states to evaluate issues in implementing formula apportionment at the international level
- Verdeling heffingsgrondslag
- What became of the EU's Common Consolidated Corporate Tax Base?
- What the OECD can learn from U.S. states about corporate income apportionment
- Why corporate taxation should mean source taxation : a response to the OECD's Actions against base erosion and profit shifting
- Why it's still not time for global formulary apportionment
- Why the OECD should take a stance on the European Commission's BEFIT proposal
- Xilinx : leaving the IRS with no options?
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/resource/pUcyNf9yOKU/" typeof="CategoryCode http://bibfra.me/vocab/lite/Concept"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/resource/pUcyNf9yOKU/">formulary apportionment</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
