It takes the average reader 7 hours and 52 minutes to read Towards a Neutral Formulary Apportionment System in Regional Integration by Shu-Chien Chen
Assuming a reading speed of 250 words per minute. Learn more
International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates 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. The author, through an 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, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding 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 presentation incorporates extensive comparison between 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. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.
Towards a Neutral Formulary Apportionment System in Regional Integration by Shu-Chien Chen is 471 pages long, and a total of 118,221 words.
This makes it 159% the length of the average book. It also has 144% more words than the average book.
The average oral reading speed is 183 words per minute. This means it takes 10 hours and 46 minutes to read Towards a Neutral Formulary Apportionment System in Regional Integration aloud.
Towards a Neutral Formulary Apportionment System in Regional Integration is suitable for students ages 12 and up.
Note that there may be other factors that effect this rating besides length that are not factored in on this page. This may include things like complex language or sensitive topics not suitable for students of certain ages.
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