Common Consolidated Corporate Tax Base: Descriptive Analysis of the Apportionment Factors

Aktivität: VortragWissenschaftlicher Vortrag (Science-to-Science)


This paper aims at evaluating the effects of the allocation procedure proposed for the Common Consolidated Corporate Tax Base (CCCTB) on an individual entity of a corporate group applying the CCCTB. The paper compares the traditional income determination used in the majority of EU member states' tax systems (Separate Accounting) with the proposed consolidation and formulary apportionment. This paper evaluates the effects of this prospective apportionment procedure on any given corporate group entity and finds that the share of the group's income allocated to a particular entity using the apportionment formula does regularly not equal the pre-consolidation income of the respective group entity. In doing so the paper focuses on the differences between income determination factors (revenues and expenditures) and income apportionment factors. The analysis shows a number of differences between these factors. It shows that various components of income determination factor are not represented in the formula apportioning the consolidated income and on the other hand the apportionment factors contain definitions that are not represented in the income determination.
Zeitraum3 Aug. 20137 Aug. 2013
EreignistitelAmerican Accounting Association Annual Meeting
VeranstaltungstypKeine Angaben