Income misattribution under formula apportionment

The Relevance of Depreciation Allowances as a Fiscal Policy Instrument: A Hybrid Approach to CCCTB?

“…Why could it be an advantage to let the apportionment factors vary for different cost and revenue categories? From Hines (2010), we know that incentives for inefficient mergers and investments are more likely to occur if the factors do not appropriately explain profits across different affiliates that are subject to formula apportionment. For instance, imagine a profitable Swedish company whose income is taxed in Sweden at a very high rate.…”

Corporate tax payments under formulary apportionment: Evidence from the financial reports of 50 major U.S. multinational firms

“…Some of the recent papers that have focused on formulary apportionment as an alternative to separate accounting include Hines (2010), De Waegenaere and Sansing (2007), Fuest et al (2007), and Devereux and Loretz (2007, 2008a, 2008b.…”

Mandatory CCCTB implementation in the Eurozone and its impact on corporate tax revenues in the Czech Republic

“…This similar result was also found by Krchnivá and Nerudová (2015). According to her, the proposed CCCTB formula factors are able to explain almost 35% of the variability in profi tability of the Czech companies, in contrast to Hines (2010), whose allocation-formula factors (the sales, assets and payroll of the U.S. companies) are able to explain almost 50% of the variability in profi tability. Furthermore, Krchnivá (2014) proves that the presence or proportion of allocation-formula factors can signifi cantly affect a country's overall tax revenues.…”