Martins, Antonio
BEFIT and formulary apportionment should Intangibles be included in the formula? / António Martins & Daniel Taborda
Resumen.
In 2021 the European Commission proposed a new framework for taxing corporate income (“Business in Europe: Framework for Income Taxation”, or BEFIT). Consolidated profits of European Union (EU) based groups will be aggregated into a single tax base, and then allocated to Member States (MS) through a formulary approach. Critical issues in defining the formula comprise how assets (including intangibles) should be reflected. This article discusses some core topics related to intangible recognition and its potential impact in the formulary approach considered in BEFIT. The topics addressed are: (1) should intangibles be included in the asset component of the formula, alongside with sales and employment? (2) considering the several types of intangible assets, which ones would merit inclusion?
ACTIVIDADES ECONOMICAS
IMPUESTO DE SOCIEDADES
BASE IMPONIBLE COMÚN CONSOLIDADA
PRIMER PILAR (OCDE)
SEGUNDO PILAR (OCDE)
APLICACION
ACTIVOS INVISIBLES
UNION EUROPEA
Taborda, Daniel
EC Tax Review 0928-2750 [print] v. 31, n. 3, June 2022, p. 131-139
BEFIT and formulary apportionment should Intangibles be included in the formula? / António Martins & Daniel Taborda
Resumen.
In 2021 the European Commission proposed a new framework for taxing corporate income (“Business in Europe: Framework for Income Taxation”, or BEFIT). Consolidated profits of European Union (EU) based groups will be aggregated into a single tax base, and then allocated to Member States (MS) through a formulary approach. Critical issues in defining the formula comprise how assets (including intangibles) should be reflected. This article discusses some core topics related to intangible recognition and its potential impact in the formulary approach considered in BEFIT. The topics addressed are: (1) should intangibles be included in the asset component of the formula, alongside with sales and employment? (2) considering the several types of intangible assets, which ones would merit inclusion?
ACTIVIDADES ECONOMICAS
IMPUESTO DE SOCIEDADES
BASE IMPONIBLE COMÚN CONSOLIDADA
PRIMER PILAR (OCDE)
SEGUNDO PILAR (OCDE)
APLICACION
ACTIVOS INVISIBLES
UNION EUROPEA
Taborda, Daniel
EC Tax Review 0928-2750 [print] v. 31, n. 3, June 2022, p. 131-139