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European Union - The Apportionment Formula under the European Proposal for a Common Consolidated Corporate Tax Base

European Union
A. Sánchez Sánchez
European Taxation, 2018 (Volume 58), No 6
14 May 2018
In this article, the author discusses the sharing mechanism suggested in the Common Consolidated Corporate Tax Base proposal, which employs three equally-weighted factors: assets, labour and sales. The author argues that although there is no doubt that the transfer pricing regime should be replaced by a more effective system, designing an adequate method requires taking into consideration the unique characteristics of the European Union and the experience with formulary apportionment in other states.
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