IMF Working Papers

The Role of Allocation in a Globalized Corporate Income Tax

By Jack M. Mintz

September 1, 1998

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Jack M. Mintz The Role of Allocation in a Globalized Corporate Income Tax, (USA: International Monetary Fund, 1998) accessed September 27, 2024
Disclaimer: This Working Paper should not be reported as representing the views of the IMF.The views expressed in this Working Paper are those of the author(s) and do not necessarily represent those of the IMF or IMF policy. Working Papers describe research in progress by the author(s) and are published to elicit comments and to further debate

Summary

The internationalization of business activity has created significant pressures on national corporate tax systems. Rather than abandon the corporate tax field, this paper predicts that governments will develop arrangements to further globalize the corporate income tax. The paper assesses the merits and limitations of allocation methods for attributing income to different jurisdictions according to formulas measuring business activity. Such methods are being used as part of transfer pricing regimes and are likely to be enhanced over time. Whatever international arrangements develop in the future, there is a role for new institutions to improve cooperative discussions among governments.

Subject: Corporate income tax, Corporate taxes, Formula apportionment, Income tax systems, National accounts, Personal income, Taxes

Keywords: Allocation method, Corporate income tax, Corporate taxation, Corporate taxes, Cost of capital, Country j, Formula apportionment, Global, Government assistance, Income tax systems, Integration regime, Personal income, Resident country, Tax harmonization, Tax rate, Transfer pricing, Withholding tax, WP

Publication Details

  • Pages:

    39

  • Volume:

    ---

  • DOI:

    ---

  • Issue:

    ---

  • Series:

    Working Paper No. 1998/134

  • Stock No:

    WPIEA1341998

  • ISBN:

    9781451855579

  • ISSN:

    1018-5941

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