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An empirical investigation into the design of an EU apportionment formula related to profit generating factors

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Abstract
The European Commission (EC) has the intention to establish a Common Consolidated Corporate Tax Base, which requires an allocation formula to fairly distribute the consolidated tax base among all group entities. A fair distribution would mean that the allocation is closely related to the profit generating factors of the underlying entities. The EC supposes that fixed tangible assets, sales and labour are the dominant factors in the generation of profit. This paper analyses the profit generating capacity of these factors and of the alternative factor intangible assets. The results show that the proposed factors only explain 28% of the variation in profit. Moreover, the results indicate that recognized intangibles do not increase R2 significantly. However, for R&D intensive companies, adding the market less book value to proxy for unrecognized intangibles increases the explanatory power with 30%. This suggests that for these companies unrecognized intangibles could be important in generating profit.
Keywords
EUROPEAN-UNION, PRODUCTIVITY, CCCTB, fairness, apportionment formula, international corporate taxation, INTANGIBLE ASSETS, European Union

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MLA
Roggeman, Annelies, et al. “An Empirical Investigation into the Design of an EU Apportionment Formula Related to Profit Generating Factors.” TRANSFORMATIONS IN BUSINESS & ECONOMICS, vol. 11, no. 3, 2012, pp. 36–56.
APA
Roggeman, A., Verleyen, I., Van Cauwenberge, P., & Coppens, C. (2012). An empirical investigation into the design of an EU apportionment formula related to profit generating factors. TRANSFORMATIONS IN BUSINESS & ECONOMICS, 11(3), 36–56.
Chicago author-date
Roggeman, Annelies, Isabelle Verleyen, Philippe Van Cauwenberge, and Carine Coppens. 2012. “An Empirical Investigation into the Design of an EU Apportionment Formula Related to Profit Generating Factors.” TRANSFORMATIONS IN BUSINESS & ECONOMICS 11 (3): 36–56.
Chicago author-date (all authors)
Roggeman, Annelies, Isabelle Verleyen, Philippe Van Cauwenberge, and Carine Coppens. 2012. “An Empirical Investigation into the Design of an EU Apportionment Formula Related to Profit Generating Factors.” TRANSFORMATIONS IN BUSINESS & ECONOMICS 11 (3): 36–56.
Vancouver
1.
Roggeman A, Verleyen I, Van Cauwenberge P, Coppens C. An empirical investigation into the design of an EU apportionment formula related to profit generating factors. TRANSFORMATIONS IN BUSINESS & ECONOMICS. 2012;11(3):36–56.
IEEE
[1]
A. Roggeman, I. Verleyen, P. Van Cauwenberge, and C. Coppens, “An empirical investigation into the design of an EU apportionment formula related to profit generating factors,” TRANSFORMATIONS IN BUSINESS & ECONOMICS, vol. 11, no. 3, pp. 36–56, 2012.
@article{3072922,
  abstract     = {{The European Commission (EC) has the intention to establish a Common Consolidated Corporate Tax Base, which requires an allocation formula to fairly distribute the consolidated tax base among all group entities. A fair distribution would mean that the allocation is closely related to the profit generating factors of the underlying entities. The EC supposes that fixed tangible assets, sales and labour are the dominant factors in the generation of profit. This paper analyses the profit generating capacity of these factors and of the alternative factor intangible assets. The results show that the proposed factors only explain 28% of the variation in profit. Moreover, the results indicate that recognized intangibles do not increase R2 significantly. However, for R&D intensive companies, adding the market less book value to proxy for unrecognized intangibles increases the explanatory power with 30%. This suggests that for these companies unrecognized intangibles could be important in generating profit.}},
  author       = {{Roggeman, Annelies and Verleyen, Isabelle and Van Cauwenberge, Philippe and Coppens, Carine}},
  issn         = {{1648-4460}},
  journal      = {{TRANSFORMATIONS IN BUSINESS & ECONOMICS}},
  keywords     = {{EUROPEAN-UNION,PRODUCTIVITY,CCCTB,fairness,apportionment formula,international corporate taxation,INTANGIBLE ASSETS,European Union}},
  language     = {{eng}},
  number       = {{3}},
  pages        = {{36--56}},
  title        = {{An empirical investigation into the design of an EU apportionment formula related to profit generating factors}},
  volume       = {{11}},
  year         = {{2012}},
}

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