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Formulary Apportionment for the Internal Market

The study is comprised of four parts. First, a theoretical concept of formulary apportionment is presented in order to define the role that formulary apportionment could take in the area of profit allocation within the Internal Market.
 
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Title:

Formulary Apportionment for the Internal Market. Doctoral Series - Vol. 17

Author(s):

Stefan Mayer

Date of publication:

June 2009

ISBN:

978-90-8722-048-8

Type of publication:

Book

Number of pages:

354

Terms:

Price includes delivery. View purchase information

Price:
€ 115 / $ 150 (VAT excl.)
Order Book -Single copy
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Title:

Formulary Apportionment for the Internal Market. Doctoral Series - Vol. 17

Author(s):

Stefan Mayer

Date of publication:

June 2009

ISBN:

978-90-8722-048-8

Type of publication:

Book

Number of pages:

354

Access:

Up to five users. View purchase information

Price:
€ 115 / $ 150 (VAT excl.)
Order Online Book
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Order 2 books from the Doctoral Series and receive a 20% discount. Order 3 or more books and receive a 30% discount. Not available in combination with any other discount. Print only.
Formulary Apportionment for the Internal Market

Why this book?

The study is comprised of four parts. First, a theoretical concept of formulary apportionment is presented in order to define the role that formulary apportionment could take in the area of profit allocation within the Internal Market. This is followed by an in-depth evaluation of the practical experiences of four jurisdictions (United States, Canada, Switzerland and Germany) with formulary apportionment at the subnational level. Next, a comprehensive proposal for harmonization on the basis of consolidation and apportionment is developed, using the insights from the foregoing theoretical considerations and comparative analysis.
 
The book concludes with an overall analysis of the merits and drawbacks of the proposed model for harmonization which suggests that consolidation and formulary apportionment could indeed represent a workable solution to numerous problems of corporate taxation within the Internal Market.
 

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This book is part of the IBFD Doctoral Series

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Main contents

 
  • Chapter One: Introduction
  • Chapter Two: Background and Theory
  • Chapter Three: Existing Formulary Apportionment Systems
  • Chapter Four: Formulary Apportionment: Proposals for the European Community
  • Chapter Five: Evaluation of the Proposals
  • Chapter Six: Conclusion

 

 

 

 

Author(s)

Stefan Mayer studied law and qualified as a lawyer in Munich. He received an LL.M. in Taxation from the London School of Economics and Political Science, and has worked as an academic assistant and scholarship holder at the Max Planck Institute for Intellectual Property, Competition and Tax Law (Munich). Currently, Mr Mayer works with the tax department of Latham & Watkins LLP in Munich.
"The author makes an important contribution to the debate over formulary apportionment versus the traditional arm’s length principle, and provides the reader with an excellent reference source....
As a reader from outside the EC, I found the book helpful in providing an overview of key developments in the EC (up to early 2008) with respect to corporate taxation...
This work is particularly insightful into how formulary apportionment could potentially be advanced in an environment outside of a sovereign country (in this case within the EC), in what has appeared to be (until recently) a receptive environment".
Read the full review.

Professor Adrian Sawyer, University of Canterbury, Christchurch, New Zealand.
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