A formulary system for dividing income among taxing jurisdictions /
" ... examines whether current arm's-length transfer pricing rules for allocating taxable income among countries should be replaced by a system of formulary apportionment. It then identifies in technical detail how, if one or more countries should decide to adopt a formulary approach, they...
|Format:||Electronic Continuing Resource|
[Arlington, Va.] :
Tax Management Inc.,
|Series:||Tax management portfolios ;
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- Detailed analysis. Starting the conversation: formulary apportionment as a replacement for the arm's-length standard
- Examining current formulary and arm's-length approaches
- Comparative assessment of formulary and arm's-length regimes
- Choosing a tax base
- Building the formula
- Suggested statutory and regulatory language for implementing formulary apportionment
- Working papers