Sign-In
Cart
Reconsidering Formulary Apportionment in the Post-BEPS Era
Hardcover
ISBN13: 9789403527291
Publisher: Kluwer Law International
Published: Dec 9 2025
Pages: 408
Weight: 1.64
Height: 0.94 Width: 6.14 Depth: 9.21
Language: English
Series on International Taxation
The OECD's Base Erosion and Profit Shifting (BEPS) Project and its maturing 'two-pillar solution' have their origin in a consensus that the existing international tax system requires significant reform, particularly in addressing the taxation of multinational enterprises (MNEs) and the digitalization of the global economy. This ground-breaking book explores in great depth how formulary apportionment (FA) - by which MNEs allocate profits across countries based on real activity in each jurisdiction, thus removing the incentive to shift reported income to low-tax locations - can become a fundamental reform option in the evolving context of international taxation.
In light of the fact that FA represents a transition from a bilateral to a multilateral mechanism, it becomes crucial to study how each 'market country' assesses its feasibility. This research selects China, thus concentrating on the dynamics of one of the world's largest economies, and demonstrating the broad implications of China's ongoing strategic FA experiment for the global tax system.
The author considers and analyses such aspects of the subject as the following:
FA-centred perspective of the evolution of the international tax regime;
complexity and nuances involved in transferring equity principles from domestic to international tax contexts;
neutrality as an evaluative benchmark in tax policy design;
impact and shaping influence of China's Belt and Road Initiative on its tax policies and strategy; and
recommended formula for an international FA regime to explore.
Included is a comparative study of the current FA systems in the United States, Canada, the European Union's Common Consolidated Corporate Tax Base (CCCTB) Proposal, and the newly introduced Pillar One Amount A. By deconstructing these systems into constituent elements, the author offers a component-by-component analysis and extracts lessons for the future architecture of international FA, with respect to highlighting its function and what practical lessons can be drawn.
With the digital transformation exacerbating existing tax system flaws to an intolerable level for most stakeholders, and as dissatisfaction with the current allocation framework has grown among both developing and developed nations, the re-emergence of formulary apportionment is becoming an increasingly concrete reality in the modern global economy. In recognition of continuing efforts to improve the international tax system, this book explores the foundational values and principles that need to be considered when developing an analytical framework for formulary apportionment, with practical insights for reform on a global level. It will be welcomed by tax professionals, policymakers, and researchers worldwide.
Also from
Wang, Jie
Rigid-Flexible Coupling Dynamics and Control of Flexible Spacecraft with Time-Varying Parameters
Li, Dong-Xu
Wang, Jie
Hardcover
Rigid-Flexible Coupling Dynamics and Control of Flexible Spacecraft with Time-Varying Parameters
Wang, Jie
Li, Dong-Xu
Paperback
Also in
General Law
Before All Is Said and Done: Practical Advice on Living and Dying Well
Watson, Suzanne
Miles, Pat
Hardcover
With Liberty and Justice for Some: How the Law Is Used to Destroy Equality and Protect the Powerful
Greenwald, Glenn
Hardcover
Boy with a Knife: A Story of Murder, Remorse, and a Prisoner's Fight for Justice
Trounstine, Jean
Paperback
The U.S. Constitution: A Comprehensive and Annotated Guide for the Modern Reader
Murray, Melissa
Hardcover
Department of Fate: The Promise, the Power, and the Collapse of America's Most Consequential Institution
Maddow, Rachel
Hardcover
Last Branch Standing: A Potentially Surprising, Occasionally Witty Journey Inside Today's Supreme Court
Isgur, Sarah
Hardcover
So Ordered: An Originalist's View of the Constitution, the Court, and Our Country
Alito, Samuel A., Jr.
Hardcover
Unreasonable Women: Three Stories of Violence, Imprisonment, and Extraordinary Survival
Van Der Leun, Justine
Hardcover
Discovering the Club: Piecing Together the Puzzling Network of Parental Pimping, Ritualistic Abuse, and Sex Trafficking
Clack, Cynthia L.
Paperback
North Carolina Notary Public Manual, 2016
Secretary of State, Nc Department
North Carolina Department of the
Secretary of State
Hardcover
Supremacy: How Rule by the Court Replaced Government by the People
Bowie, Nikolas
Renan, Daphna
Hardcover
Federal Rules of Civil Procedure; 2026 Edition: With Statutory Supplement
Michigan Legal Publishing Ltd
Paperback
Nolo's Guide to Social Security Disability: Getting & Keeping Your Benefits
Morton III, David A.
Paperback
Social Security, Medicare & Government Pensions: Get the Most Out of Your Retirement and Medical Benefits
Matthews, Joseph
Paperback
The Price of Mercy: Unfair Trials, a Violent System, and a Public Defender's Search for Justice in America
Galvin Almanza, Emily
Hardcover
Five Bullets: The Story of Bernie Goetz, New York's Explosive '80s, and the Subway Vigilante Trial That Divided the Nation
Williams, Elliot
Hardcover
The Water Remembers: My Indigenous Family's Fight to Save a River and a Way of Life
Cordalis, Amy Bowers
Hardcover
Our Minds Were Always Free: A History of How Black Brilliance Was Exploited--And the Fight to Retake Control
Davis, Lisa E.
Hardcover
Captain's Dinner: A Shipwreck, an Act of Cannibalism, and a Murder Trial That Changed Legal History
Cohen, Adam
Hardcover
Searching for Jane Crow: Black Women and Mass Incarceration in America from the Auction Block to the Cell Block
Leflouria, Talitha L.
Hardcover
The Criminal Law Handbook: Know Your Rights, Survive the System
Bergman, Paul
Berman, Sara J.
Paperback
Your Data Will Be Used Against You: Policing in the Age of Self-Surveillance
Ferguson, Andrew Guthrie
Hardcover
One in Five: Why Child Sexual Abuse Is Our Biggest Public Health Crisis--And What We Can Do to Stop It
Letourneau, Elizabeth J.
Malone, Luke
Hardcover
Revenge for the Sixties: Sam Alito and the Triumph of the Conservative Legal Movement
Canellos, Peter S.
Hardcover
Robert's Rules of Order Newly Revised in Brief, 3rd Edition
Robert, Henry M., III
Honemann, Daniel H.
Balch, Thomas J.
Paperback
Medical Terminology Made Simple: Easily Learn, Memorize, and Pronounce Medical Terms
Temple, John, MD
Paperback
The Pain Brokers: How Con Men, Call Centers, and Rogue Doctors Fuel America's Lawsuit Factory
Chamblee Burch, Elizabeth
Hardcover
The Public Domain: Find and Use Free Content for Your Website, Book, App, Music, Video, Art, and More
Secor, Glen
Paperback
Oops...That's Illegal!: A Handbook for the Wildly Curious (and the Accidental Outlaw)
Mandell, Mike
Hardcover
When Companies Run the Courts: How Forced Arbitration Became America's Secret Justice System
Ballou, Brendan
Hardcover
Getting Permission: Using & Licensing Copyright-Protected Materials Online & Off
Stim, Richard
Paperback
The Trustee's Legal Companion: A Step-By-Step Guide to Administering a Living Trust
Hanks, Liza
Zolla, Carol Elias
Buckley, Shaila
Paperback
Living Trusts for Everyone: Why a Will Is Not the Way to Avoid Probate, Protect Heirs, and Settle Estates (Second Edition)
Sharp, Ronald Farrington
Paperback
Pink Crime: Fighting Against the Criminalization of Motherhood, Pregnancy, and Queer Identity
Beety, Valena
Hardcover
Lawless: How the Supreme Court Runs on Conservative Grievance, Fringe Theories, and Bad Vibes
Litman, Leah
Paperback
The Constitution Cannot Save Us: Why We Can No Longer Rely on Our Founding Document
Seidman, Louis Michael
Hardcover
Dig Me a Grave: The Inside Story of the Serial Killer Who Seduced the South
Assael, Shaun
Harpootlian, Richard A.
Hardcover
Federal Rules of Evidence; 2026 Edition (Casebook Supplement): With Advisory Committee notes, Rule 502 explanatory note, internal cross-references, qu
Michigan Legal Publishing Ltd
Paperback
Federal Rules of Evidence; 2026 Edition: With Internal Cross-References
Michigan Legal Publishing Ltd
Paperback
Is the Government Legally Killing Us?: Is the Evidence Obvious? How Fear of Death and the Illusion of Freedom Turn Us Into Accomplices to Evil
(Scott Schara), Grace's Dad
Paperback
The U.S. Constitution and Other Writings (Deluxe Leatherbound Edition)
Editors of Canterbury Classics
Hardcover
Bone Valley: A True Story of Injustice and Redemption in the Heart of Florida
King, Gilbert
Hardcover
J.K. Lasser's Small Business Taxes 2027: Your Complete Guide to a Better Bottom Line
Weltman, Barbara
Paperback
The Constitution of the United States of America: The Declaration of Independence, The Bill of Rights
Founding Fathers
Paperback
Represent Yourself in Court: Prepare & Try a Winning Civil Case
Bergman, Paul
Berman, Sara J.
Paperback
No Loose Ends: The Smart & Slightly Morbid Guide to Estate Planning & End-Of-Life Tasks
Zuckerman, Adam
Hardcover
The Cases That Haunt Us: From Jack the Ripper to JonBenet Ramsey, the Fbi's Legendary Mindhunter Sheds Light on the Mysteries That Won't Go Away
Douglas, John E.
Olshaker, Mark
Paperback
Understanding Living Trusts(R): How You Can Avoid Probate, Keep Control, Save Taxes, and Enjoy Peace of Mind
Schumacher, Vickie
Paperback
Iras, 401(k)S & Other Retirement Plans: Strategies for Taking Your Money Out
Shea, Tracy
Slesnick, Twila
Paperback
Stitching Freedom: A True Story of Injustice, Defiance, and Hope in Angola Prison
Tyler, Gary
Hardcover
The Presidential Pardon: The Short Clause with a Long, Troubled History
Prakash, Saikrishna Bangalore
Hardcover
55 Successful Harvard Law School Application Essays, 2nd Edition: With Analysis by the Staff of the Harvard Crimson
Staff of the Harvard Crimson
Paperback
The Federalist: A Commentary on the Constitution of the United States
Jay, John
Hamilton, Alexander
Madison, James
Paperback
Terrible Stuff Damaging Everybody: The True Story of Lies and Libel in Dominion V. Fox
Rosenberg, Ian
Hardcover
38 Londres Street: On Impunity, Pinochet in England, and a Nazi in Patagonia
Sands, Philippe
Hardcover
Every Californian's Guide to Estate Planning: Wills, Trust & Everything Else
Hanks, Liza W.
Paperback
Little Book of Restorative Justice & Community: Reclaiming Connection and Responsibility for Our Neighbors
Wilson, Sheryl
Morneau, Caitlin
Paperback
Lawless: How the Supreme Court Runs on Conservative Grievance, Fringe Theories, and Bad Vibes
Litman, Leah
Hardcover
Until the Last Yoke Is Broken: The Constitutional Vision of Frederick Douglass
Rebeiro, Bradley N.
Hardcover
Beyond the Body Farm: A Legendary Bone Detective Explores Murders, Mysteries, and the Revolution in Forensic Science
Bass, Bill
Jefferson, Jon
Paperback
Fireproof: A Five-Step Model to Take Your Law Firm from Unpredictable to Wildly Profitable
Morse, Mike
Nachazel, John
Hardcover
Redemption: Faith, Justice, and Sisterhood on Death Row (Large Print Edition)
Wright, Lawrence
Paperback
Hitler's American Model: The United States and the Making of Nazi Race Law
Whitman, James Q.
Paperback
Contempt of Court: The Turn-Of-The-Century Lynching That Launched a Hundred Years of Federalism
Curriden, Mark
Phillips, Leroy
Paperback
The Only Living Trusts Estate Planning Guide: Protect Your Assets, Avoid Probate, Slash Taxes and Secure Your Heirs' Future.
Sterling, Thayer
Paperback
Special Needs Trusts: Protect Your Child's Financial Future
Urbatsch, Kevin
Farinas Jones, Jessica
Paperback
The U.S. Constitution - Anti-Federalist Edition
Adams, Samuel
Henry, Patrick
Convention, Constitutional
Paperback