The labour apportionment factor for a common consolidated corporate tax base : a double-edged sword

The European Commission has worked for a few years on the implementation of a common consolidated corporate tax base. This article analyses the conceptual justification and the usefulness of applying a labour apportionment factor with regard to the economic impact. A brief overview on the apportionment scheme proposed by the CCCTB Working Group is presented, with subsequent focus on the use of the labour apportionment factor, considering the conceptual justification for using the labour factor; the labour factor as a proxy for intangibles not included in the assets factor; matters of administrative feasibility; and the impact on unemployment.