BEFIT and formulary apportionment should Intangibles be included in the formula? António Martins & Daniel Taborda
By: Martins, Antonio
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Contributor(s): Taborda, Daniel.
Material type: 
ArticleSubject(s): ACTIVIDADES ECONOMICAS | IMPUESTO DE SOCIEDADES | BASE IMPONIBLE COMÚN CONSOLIDADA | PRIMER PILAR (OCDE) | SEGUNDO PILAR (OCDE) | APLICACION | ACTIVOS INVISIBLES | UNION EUROPEA
In:
EC Tax Review v. 31, n. 3, June 2022, p. 131-139Summary: 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?
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 2141-B/2022/3-4 (Browse shelf) | Available | OP 2141-B/2022/3-4 |
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| OP 2141-B/2022/3-1 Should we cut "final" losses? | OP 2141-B/2022/3-2 The shortcomings of the EU Public Country-by-Country Reporting Directive | OP 2141-B/2022/3-3 "VAT gap" estimation | OP 2141-B/2022/3-4 BEFIT and formulary apportionment | OP 2141-B/2022/3-5 Blocking the gap | OP 2141-B/2022/3-6 Disproportionate taxation and the right to property | OP 2141-B/2022/3-7 Order in Skelleftea Industrihus AB |
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?
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