Company Tax Reform in the European Union: Guidance from the United States and Canada on Implementing Formulary Apportionment in the EU
Springer Science & Business Media, Mar 14, 2006 - Business & Economics - 122 pages
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 Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.
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adopted allocation apply apportion apportionment factors apportionment formula apportionment tax rate arm's length pricing arm's length principle basis calculate Canada Canadian provinces capital chapter common formula common tax base company tax reform company tax system compliance costs corporate income tax corporate tax countries discussion distribute income dividend imputation double taxation economic effect employees entity European Commission European Union example foreign formulary apportionment formulary methods gross receipts Hellerstein holding company income distribution income shifting issues jurisdiction Marks & Spencer Member State tax multinational enterprises OECD operating payroll factor percent permanent establishment profits property factor revenue rules sales formula separate accounting share shift income statutory tax rate subsidiaries tax authorities tax competition tax haven tax planning tax purposes tax return tax treaties taxable group taxable income taxpayer tion transactions transfer pricing U.S. Supreme Court U.S. Treasury Department Unilever unitary business water's edge weights Weiner worldwide combined reporting