Quotation Petutschnig, Matthias. 2013. Common Consolidated Corporate Tax Base: Descriptive Analysis of the Apportionment Factors. American Accounting Association - Annual Meeting, Anaheim (CA), Vereinigte Staaten/USA, 03.08-07.08.


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Abstract

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.

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Publication's profile

Status of publication Published
Affiliation WU
Type of publication Paper presented at an academic conference or symposium
Language English
Title Common Consolidated Corporate Tax Base: Descriptive Analysis of the Apportionment Factors
Event American Accounting Association - Annual Meeting
Year 2013
Date 03.08-07.08
Country United States/USA
Location Anaheim (CA)

Associations

People
Petutschnig, Matthias (Details)
Organization
Tax Management Group AB (Details)
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