The case for formulary apportionment

Journal
Hellerstein, W.
International Transfer Pricing Journal 2005 (Volume 12), No. 3
FormatPDF
EUR
40
| USD
45
(VAT excl.)

The author gives an overview of arguments for and against formulary apportionment, concluding that if tax rules are to reflect the underlying economic reality to which they apply, the arm's length/separate-geographic-accounting standard will ultimately yield to formulary apportionment as the preferred method of income allocation in the 21st century.