Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/271763 
Year of Publication: 
2022
Series/Report no.: 
CESifo Working Paper No. 10119
Publisher: 
Center for Economic Studies and ifo Institute (CESifo), Munich
Abstract: 
Almost 140 countries have agreed to reallocate the rights to tax international corporate profits and to introduce minimum tax rates. The agreed plan is the product of pragmatism and a search for consensus, but ambitious. It includes steps towards unitary taxation to be established by a multilateral convention that the world has not yet seen in comparable format. This paper argues for a reform that retains separate entity accounting and addresses the flaws in the current system of corporate taxation at their root rather than merely fixing symptoms. To this end, a reform aimed specifically at the rules governing the taxation of intangible assets is recommended.
Subjects: 
OECD/G20 BEPS Project
formula apportionment
separate entity accounting
Shapley assignment of taxing rights
residual profit allocation/splitting
JEL: 
H25
F23
M48
Document Type: 
Working Paper
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