Wildy Logo
(020) 7242 5778
enquiries@wildy.com

Book of the Month

Cover of Borderlines in Private Law

Borderlines in Private Law

Edited by: William Day, Julius Grower
Price: £90.00

Lord Denning: Life, Law and Legacy



  


Welcome to Wildys

Watch


NEW EDITION
The Law of Rights of Light 2nd ed



 Jonathan Karas


Offers for Newly Called Barristers & Students

Special Discounts for Newly Called & Students

Read More ...


Secondhand & Out of Print

Browse Secondhand Online

Read More...


Towards a Neutral Formulary Apportionment System in Regional Integration: The Case of European Union


ISBN13: 9789403532769
Published: March 2023
Publisher: Kluwer Law International
Country of Publication: Netherlands
Format: Hardback
Price: £130.00



This is a Print On Demand Title.
The publisher will print a copy to fulfill your order. Books can take between 1 to 3 weeks. Looseleaf titles between 1 to 2 weeks.

Also available as
£130.00

Towards a Neutral Formulary Apportionment System in Regional Integration is a crucial and foresighted book demonstrating how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. Through intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, the author elucidates how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility.

What’s in this book:

Delving deep into the debates around formulary apportionment and its theoretical foundations, the book furnishes a prototype for reconstructing the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more:

  • theorising public benefits to be represented by taxation,
  • reorganising different economic theories about tax neutrality and tax justice,
  • advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach,
  • designing the logical formulary apportionment system for digital economy,
  • ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations,
  • reducing the tax system’s complexity and the administrative burden it imposes on firms,
  • eliminating transfer pricing complexity for intra-firm transactions,
  • achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula,
  • application of ‘destination-based’ rule for attributing the sales factor, and
  • replacing the traditional permanent establishment nexus with a ‘factor presence nexus’

The book comprises an in-depth comparison of the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation.

How this will help you:

Formulary apportionment is gaining increasing acceptance and attention as a possible option to address the problem of base erosion and profit shifting. This book will prove indispensable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in constituting and executing an effective and market-neutral FA system.

Subjects:
EU Law, Taxation
Contents:
List of Figures
List of Tables
List of Abbreviations
Preface
Acknowledgement

Chapter 1. Introduction
Chapter 2. The Normative Framework: Implementing the Benefit(s) Principle to Achieve Market Neutrality
Chapter 3. An Overview of Policy Options Towards a Benefit-Based Market-Neutral Formula: Putting Old Wine in a New Bottle
Chapter 4. Towards the Market-Neutral Sales Factor: A Customer-Centred Destination-Based Sales Factor
Chapter 5. Towards the Market-Neutral Labour Factor
Chapter 6. Towards the Market-Neutral Asset Factor
Chapter 7. Towards Market-Neutral Industry-Specific Formulas: Rediscovering the Roots of Formulary Apportionment
Chapter 8. The Procedural Weapon Towards a Market-Neutral Apportionment Result: The Safeguard Clause
Chapter 9. Conclusions

Bibliography
Table of Legislation
Index

Series: EUCOTAX Series on European Taxation

Short-Term Rental Platforms as Deemed Suppliers in the EU VAT System (eBook) ISBN 9789403543185
Published September 2024
Kluwer Law International
£81.00
(ePub)
Buy
Short-Term Rental Platforms as Deemed Suppliers in the EU VAT System ISBN 9789403543086
Published September 2024
Kluwer Law International
£81.00
Aggrieved Taxpayers versus Tax Authorities ISBN 9789403522081
Published May 2024
Kluwer Law International
£113.00
£111.00
(ePub)
Buy
£111.00
Special Tax Zones and EU Law: Theory, Implementations and Future Challenges ISBN 9789403518855
Published January 2020
Kluwer Law International
£112.00
European VAT and the Sharing Economy ISBN 9789403514352
Published October 2019
Kluwer Law International
£116.00
£86.00
Sales Promotion Techniques and VAT in the EU ISBN 9789403508610
Published March 2019
Kluwer Law International
£115.00
£111.00
Investment Fund Taxation: Domestic Law, EU Law, and Double Taxation Treaties ISBN 9789041196699
Published May 2018
Kluwer Law International
£107.00
National Legal Presumptions and European Tax Law ISBN 9789041166135
Published February 2018
Kluwer Law International
£154.00
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
£167.00
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
£139.00
Transfer Pricing in the US: A Practical Guide ISBN 9789041191960
Published September 2017
Kluwer Law International
£113.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed (eBook) ISBN 9789041161437
Published September 2017
Kluwer Law International
£188.00
(ePub)
Buy
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed ISBN 9789041161352
Published September 2017
Kluwer Law International
£188.00
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
£211.00
£142.00
(ePub)
Buy
Corporate Tax Base in the Light of IAS/IFRS and EU Directive 2013/34: A Comparative Approach ISBN 9789041167453
Published July 2016
Kluwer Law International
£142.00
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
£167.00
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
£154.00
CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
Edited by: Dennis Weber
ISBN 9789041138729
Published May 2012
Kluwer Law International
£178.00
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
£178.00
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
£167.00
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
£167.00
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
£167.00
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
£173.00
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
£167.00
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
£224.00
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
£177.00
Limitation on Benefits Clauses in Double Taxation Conventions ISBN 9789041123701
Published December 2005
Kluwer Law International
Out of print
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
£222.00
£187.00
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
£374.00
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
£290.00
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
£298.00
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
£249.00
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
£268.00
The Principle of Equality in European Taxation ISBN 9789041196934
Published October 1999
Kluwer Law International
£243.00
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
£262.00