International taxation and the frustrations of formulary apportionment estimation
本文系统分析了从独立交易原则转向公式分配制度时，实证研究者面临的数据和地缘政治约束，包括利润计算、权重设定等六大挑战，对政策制定者和研究者有参考价值。
Purpose The purpose of this paper is to investigate the challenges faced by empirical researchers investigating a shift from taxing multinational entities using the arm’s length system to a formulary apportionment system. Theoretically, a shift should increase global tax collections as profits currently attributed to low or no tax jurisdictions are allocated to jurisdictions with true input or output factors and shift the allocation between these countries. Before any jurisdiction seriously contemplated a shift from an arm’s length allocation system to a formulary apportionment regime, however, it would want to estimate the revenue impact of such a change. Design/methodology/approach The paper systematically analyzes empirical papers that attempt to estimate the effects of formulary apportionment on country and global income revenue collected to determine the challenges faced by researchers. Findings The paper determines that there are both data and geo-political constraints that relate to (1) the method used to calculate the global profits of a multinational enterprise, (2) whether jurisdictions wish to adopt a global or regional formulary apportionment, (3) the weightings to be given to the factors used in the formulary apportionment, (4) the challenges of measuring sales at destination and the viability of surrogate measurements, (5) whether natural resources should be included in the measurement of the capital input factor, and (6) whether a redistribution objective should be included in the profit allocation formula. Originality/value Estimating the changes is challenging both in terms collecting the data needed for the calculations and the choice of design options to be tested. The paper provides synthesized knowledge in relation to the difficulties in estimating the effects of moving to a formulary apportionment model for taxing multinational entities.