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The allocation of multinational business income

Richard E. Krever, François Vaillancourt

The Allocation of Multinational Business Income' is a global guide to formula apportionment providing a comprehensive understanding of aspects of the formulary apportionment option. Although an arm's length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union's CCCTB proposals. In this book, a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States address this actively debated topic, in respect of both its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems.

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