Common Consolidated Corporate Tax Base: A “Fair Share” of the Tax Base?

Even though the OECD is making a Herculean effort to address the question of how international tax bases should be allocated given the lack of a higher, international authority, this question remains one of the biggest obstacles to global streamlining of taxation of businesses. How should a company with cross-border activities determine a “fair share” of profit for each state? This question has also haunted the European Union.