Here, the authors present their own analysis of the Commission's Home State Taxation Proposal. Some unexpected effects are described, e.g. like distortion of competition (between participating and non-participating SMEs), and tax planning opportunities within groups. Subsequently, the required formulatory apportionment is discussed, e.g. whether the same formula can be applied to all business sectors. Relevant factors constitute assets, sales and payroll, which are each of them examined. The article finishes with an analysis of the prerequisites for participation in the pilot and an assessment of the scope of a possible pilot.