There have been welcome comments over the weekend from the EU and Germany on support for a unitary tax base for corporation tax. This has always been a condition of a properly functioning common market and is long overdue.
Now Germany also needs to support public country-by-country reporting which could help underpin such a tax base. Then we'd know they were serious.
Meanwhile the UK Treasury will, no doubt, be working out how to undermine such tax unity in a post-Brexit world. Which is depressing.
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In the Apple state aid verdict on 30.08.16 the EU commission have said:
“This decision does not call into question Ireland’s general tax system or its corporate tax rate.” and
“More specifically, profits must be allocated between companies in a corporate group, and between different parts of the same company, in a way that reflects economic reality. This means that the allocation should be in line with arrangements that take place under commercial conditions between independent businesses”
That makes unitary taxation, where some profits are attributed to the location of the person doing their shopping, look a long way off.
No it does not
The OECD residual profit split method of allocation of profits now more heavily endorsed under BEPS is a close approximation to unitary because it does allocate profit to where it should be earned
And maybe you have not noticed that CBCR is about source not destination of sales
I would personally have the sales formula split