The Unitary Tax Method and Its Underlying Unitary Business Doctrine: a Paradigm for Future Eu Corporate Taxation

The co-existence of 27 different tax systems across Europe might be the most profound argument for reconsidering the current company taxation system in the EU. The battle of "slicing" a taxpayer's allocable "pie of profits" fairly and accurately becomes an issue of massive importance. The current international standard is the separate accounting approach. Every single transaction within a multinational company has to be calculated at "arm's length". Its imperfection becomes very apparent, from an economic perspective as well as from an administrative point of view. Consequently, an extensive company tax reform is crucial when shaping Europe's future. This paper discusses the landscape for company tax reform in the EU and illustrates the chances and challenges of replacing the current accounting method by an approach similar to the US unitary taxation method. Analyzing the US unitary taxation approach and its underlying unitary business doctrine partly applied to US multistate taxation allows establishing a master plan for a more competitive future EU corporate taxation system under formulary apportionment.