Formulary apportionment – Martin Hearson

Some academic thoughts on international tax reform

Since my post last week on unitary taxation, I’ve read a couple of academic papers that give useful perspectives on some of the questions I raised. US states and unitary taxation First up, Lessons for International Tax Reform from the U.S. State Experience Under Formulary Apportionment by Kimberly Clausing. One of the concerns I raised… Continue reading Some academic thoughts on international tax reform

Some political questions for Unitary Taxation

It sometimes feels like, when discussing unitary taxation [pdf], one is expected to self-identify as either a UT advocate, interested in how it could be made a reality, or a sceptic, determined to defend the status quo. I’m neither. As a political scientist, I want to understand (among other things) how our international tax instruments… Continue reading Some political questions for Unitary Taxation

UN transfer pricing manual: what Brazil, India and China do differently

‘Country Practices’. The title of Chapter 10 of the new United Nations Practical Manual on Transfer Pricing [pdf] doesn’t exactly set the pulse racing. But as I noted in my blog on the manual as a whole, this document is politically very significant. It’s probably the only detailed description of Brazil, China, India and South… Continue reading UN transfer pricing manual: what Brazil, India and China do differently

Unitary taxation, Barclays and Africa

I just read the Tax Justice Network briefing which is explained in Richard Murphy’s blog title “Barclays and HSBC make the case for unitary tax in the UK – because we’d have collected £2.6 billion more in 4 years.” Now I haven’t checked out the UK figures at all, but the inclusion of Barclays piqued… Continue reading Unitary taxation, Barclays and Africa

Is it time to tax companies on the basis of sales, not profits?

corporation tax is paid on profits, not sales, for a start. That KPMG’s Chris Morgan felt the need to clarify this point in Tax Journal got me thinking. It seems that, in the wake of the recent spate of corporate tax scandals, there’s a confluence of opinion between the general public and many tax scholars.… Continue reading Is it time to tax companies on the basis of sales, not profits?