The International Centre for Tax and Development  at the Institute for Development Studies at the University of Sussex has put out this call for research proposals. I would strongly recommend it as a good field of study:

Research Topic: Unitary Taxation of Transnational Corporations

Contact Details:

Adam Randon | Tel:+44 (0)1273 915718 |Email: a.randon@ids.ac.uk

The ICTD invites interested researchers to submit proposals for research on Unitary Taxation (UT).

The research proposal should be approached from the perspective of developing countries, with a focus on the following issues:

Experience of the Unitary approach

• What can be learned from previous experience of applying Unitary Taxation, both internationally and within federal states, especially the US?
• How far is the current EU proposal for a common consolidated tax base compatible with the US state version?
• How does UT compare with the present system, in terms of ease of operation, as well as outcomes, for firms and for countries?

Harmonisation of definitions of the tax base

• What are the main divergences between countries in their tax base definitions?
• Could convergence be achieved, e.g. by reference to international accounting standards? 
• What might be the economic implications or welfare effects of tax base harmonisation? 
• What would be the implications for administration of tax assessments, compared with the present system.

Identifying a unitary business

• What would be the implications of strict or loose definitions of what constitutes a unitary business? 
• How would or should these definitions apply to e.g. joint venture arrangements which are common in developing countries? 
• What would be the implications for administration of tax assessments, compared with the present system.

The apportionment formula

What would be the effect of different variations of the usual 3-factor formula (assets-labour-sales) (i) on international allocation of the tax base of Transnational Corporations (TNCs), and (ii) in welfare-economic terms? How would allocation on such a basis differ from that under the present system?

Managing a transition to UT

• How far can aspects of the UT approach, e.g. the requirement to submit consolidated accounts (a combined report) be compatible with the existing legal framework especially in tax treaties? 
• What are the implications for this framework of a gradual shift, e.g. by regional adoption of UT, such as under the Common Consolidated Corporate Tax Base (CCCTB)? 
• What changes to the legal framework would be necessary for a transition to UT, and how could it be managed with least disruption? 
• What would be the administrative cost implications especially for developing countries of such a transition?

For more information, see Research into Unitary Taxation of Transnational Corporations