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Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2)

Sadiq, Kerrie (2012) Taxation of multinational banks : using formulary apportionment to reflect economic reality (Part 2). Journal of International Taxation, 23(2), pp. 54-62.

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Abstract

As stated in Part 1 of this article, formulary appointment does not attempt to undertake a transactional division of a highly integrated multinational entity; rather, it allocates income to the jurisdictions based on economically justifiable formula. This article argues that the unitary taxation model is superior to the current arms-lenght model for the taxation of multinational banks despite significant implementation, complicance and enforcement issues.

Part one of the article gave some background on the taxation of multinational banks, followed by a discussion of their uniqueness, and the theoretical benefits of the unitary tax model for multinational banking. Part 2 below covers the practical implications of accepting formulary apportionment as an 'optimal' regime for taxing multinational banks.

Impact and interest:

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ID Code: 49761
Item Type: Journal Article
ISSN: 1049-6378
Subjects: Australian and New Zealand Standard Research Classification > COMMERCE MANAGEMENT TOURISM AND SERVICES (150000) > ACCOUNTING AUDITING AND ACCOUNTABILITY (150100) > Accounting Auditing and Accountability not elsewhere classified (150199)
Divisions: Current > QUT Faculties and Divisions > QUT Business School
Current > Schools > School of Accountancy
Copyright Owner: Copyright 2012 Thomson Reuters
Deposited On: 19 Apr 2012 08:08
Last Modified: 13 Jun 2013 00:43

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