Proposal for an Enhanced CCTB as Alternative to a CCCTB with Formulary Apportionment

World Tax Journal, Volume 4, Issue 2, June 2012, pp. 125-150

Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2012-01

28 Pages Posted: 29 Feb 2012 Last revised: 27 May 2013

See all articles by Erik Röder

Erik Röder

Max Planck Institute for Tax Law and Public Finance

Date Written: February 28, 2012

Abstract

Replacing separate accounting and arm’s length pricing by consolidation and formulary apportionment lies at the heart of the Commission’s proposal for a Common Consolidated Corporate Tax Base. This article shows that such a radical change of system is not justified as it would not solve the problems related to the arm’s length standard, but combine them with additional drawbacks of consolidation and formulary apportionment. Instead, the article pleads for an enhanced Common Corporate Tax Base without consolidation as an alternative approach for the reduction of tax obstacles to the internal market.

Suggested Citation

Röder, Erik, Proposal for an Enhanced CCTB as Alternative to a CCCTB with Formulary Apportionment (February 28, 2012). World Tax Journal, Volume 4, Issue 2, June 2012, pp. 125-150, Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2012-01, Available at SSRN: https://ssrn.com/abstract=2012640 or http://dx.doi.org/10.2139/ssrn.2012640

Erik Röder (Contact Author)

Max Planck Institute for Tax Law and Public Finance ( email )

Marstallplatz 1
Munich, 80539
Germany

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