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The Role of Allocation in a Globalized Corporate Income Tax
Author: Mr. Jack M. Mintz1
  • 1 https://isni.org/isni/0000000404811396, International Monetary Fund
Series:
IMF Working Papers
Volume/Issue:
Volume 1998: Issue 134
Language:
English
Publication Date:
01 Sep 1998
DOI:
https://doi.org/10.5089/9781451855579.001
ISBN:
9781451855579
ISSN:
1018-5941
Pages:
39
Keywords:
WP; tax rate; transfer pricing; cost of capital; withholding tax; Corporate taxation; tax harmonization; allocation method; country j; government assistance; resident country; integration regime; Corporate income tax; Personal income; Formula apportionment; Income tax systems; Corporate taxes; Global
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IMF Working Papers describe research in progress by the author(s) and are published to elicit comments and to encourage debate. The views expressed in IMF Working Papers are those of the author(s) and do not necessarily represent the views of the IMF, its Executive Board, or IMF management.
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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.
Cover IMF Working Papers
IMF Working Papers
ISSN:
1018-5941
Publisher:
International Monetary Fund

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