Please use this identifier to cite or link to this item: https://hdl.handle.net/10419/76504 
Year of Publication: 
2003
Series/Report no.: 
CESifo Working Paper No. 1004
Publisher: 
Center for Economic Studies and ifo Institute (CESifo), Munich
Abstract: 
Motivated by the EU Commission‘s suggested company tax reforms, this paper investigates how cross-border loss offset and formulary apportionment of a consolidated tax base affect the investment and transfer pricing behaviour of a multijurisdictional firm, and how they affect the behaviour of governments potentially engaged in tax competition. The paper shows that cross-border loss offset mitigates both the reactions of a multijurisdictional firm to tax changes and the amount of tax competition engaged in by governments. However, formulary apportionment (with a consolidated tax base) boosts the sensitivity of firms to tax changes and increases the scope for interjurisdictional tax competition as well. For governments, formulary apportionment operates like a risk-sharing or partial equalisation mechanism.
Subjects: 
cross border loss offset
multinational firms
tax competition
Document Type: 
Working Paper
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