Company Tax Reform in the European Union

Company Tax Reform in the European Union

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Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.... Territories Nunavut Yukon TOTAL Source: Modified from Schedule 5 Allocation of Taxable Income, Revenue Canada. ... For example, the property factor may include intangible property, such as coin and currency, loans related to in-state property and credit card receivables if the fees ... For example, an airline company may apportion its income solely on the basis of total revenue aircraft miles flown inanbsp;...

Title:Company Tax Reform in the European Union
Author: Joann Martens-Weiner
Publisher:Springer Science & Business Media - 2006-03-14

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