ФОРМУЛЬНОЕ РАСПРЕДЕЛЕНИЕ: ВОПРОСЫ ТЕОРИИ

Abstract

The current international tax system, which is based on separate accounting for corporate affiliates trading at arm’s length prices, is increasingly viewed as prone to abuse. Multinational enterprises have become adept at manipulating the rules of the current system to shift profits from high-tax to low-tax (or no-tax) jurisdictions. At the same time, each country’s law sets corporate income tax rates as well as bases, which may be eroded by tax incentives provided via legislation or ministerial discretion. These laws are further overlaid by a network of bilateral tax treaties, which alter the tax treatment of investment depending on the particular source and residence countries involved. This makes administration and enforcement of the corporate income tax costly, especially for developing country governments. Corporate compliance costs also increase with complexity. One fundamental reform proposal is to replace the current system of separate accounting by formulary apportionment.