IDEAS home Printed from https://ideas.repec.org/a/vrs/ceuecj/v9y2022i56p269-290n5.html
   My bibliography  Save this article

Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison

Author

Listed:
  • Müller-Thomczik Sandra

    (Fern Universität Hagen, Faculty of Business Administration and Economics, Universitätsstr. 41, 58097 Hagen, Germany)

  • Reiter Lukas

    (Fern Universität Hagen, Faculty of Business Administration and Economics, Universitätsstr. 41, 58097 Hagen, Germany)

Abstract

The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting trade tax and corporate income tax. This conceptual study, presented at the European Accounting Association (EAA) Congress in Bergen in 2022, will examine whether the German method of splitting could lead to some lessons for an appropriate design for an international profit distribution formula. Methodologically, we use a two-step approach: First, we compare the designs, and then we juxtapose both on a factual level. Next, we ask what the objectives these mechanisms have; do they even coincide? If the goals are not comparable, one cannot indisputably serve as a model for the other. We determine that, even though there are partial deviations, a closer look reveals significant overlaps; however, the German implementation is far from consistent and prioritises practicability. This leads us to our main result: The German system makes a clear value decision towards practicability, although there is a different set of aims. For the implementation of formulaic EU profit sharing, the lesson to be learned is that practicability should play a central role in the design of the formula. This lesson is important and helpful to accompany and support the implementation process in the EU.

Suggested Citation

  • Müller-Thomczik Sandra & Reiter Lukas, 2022. "Splitting of Corporate Taxes in Germany and Formulaic Distribution of a CCCTB – Critical Comparison," Central European Economic Journal, Sciendo, vol. 9(56), pages 269-290, January.
    • Handle: RePEc:vrs:ceuecj:v:9:y:2022:i:56:p:269-290:n:5
    DOI: 10.2478/ceej-2022-0016
    as

    Download full text from publisher

    File URL: https://doi.org/10.2478/ceej-2022-0016
    Download Restriction: no
    File URL: https://libkey.io/10.2478/ceej-2022-0016?utm_source=ideas
    LibKey link: if access is restricted and if your library uses this service, LibKey will redirect you to where you can use your library subscription to access this item
    ---><---

    References listed on IDEAS

    as
    1. Walter Hellerstein & Charles E. McLure, Jr., 2004. "The European Commission's Report on Company Income Taxation: What the EU Can Learn from the Experience of the US States," International Tax and Public Finance, Springer;International Institute of Public Finance, vol. 11(2), pages 199-220, March.
    2. Joann Martens Weiner, 2005. "Formulary Apportionment and Group Taxation in the European Union: Insights from the United States and Canada," Taxation Papers 8, Directorate General Taxation and Customs Union, European Commission, revised Mar 2005.
    3. Musgrave, Peggy B, 1972. "International Tax Base Division and the Multinational Corporation," Public Finance = Finances publiques, , vol. 27(4), pages 394-413.
    4. Dirk Kiesewetter & Tobias Steigenberger & Matthias Stier, 2018. "Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation, intragroup debt, and leases," Journal of Business Economics, Springer, vol. 88(9), pages 1029-1060, December.
    5. Thomas Eichner & Marco Runkel, 2008. "Why the European Union Should Adopt Formula Apportionment with a Sales Factor," Scandinavian Journal of Economics, Wiley Blackwell, vol. 110(3), pages 567-589, September.
    Full references (including those not matched with items on IDEAS)

    Most related items

    These are the items that most often cite the same works as this one and are cited by the same works as this one.
    1. Dietrich, Maik, 2009. "Entscheidungswirkungen einer europaweit harmonisierten Konzernbesteuerung [Impacts of European Group Taxation]," MPRA Paper 59870, University Library of Munich, Germany.
    2. Marcel Gérard, 2006. "Reforming the Taxation of Multijurisdictional Enterprises in Europe, a Tentative Appraisal," CESifo Working Paper Series 1795, CESifo.
    3. repec:prg:jnlpep:v:preprint:id:514:p:1-17 is not listed on IDEAS
    4. Marcel Gerard, 2006. "Reforming the taxation of Multijurisdictional Enterprises in Europe, "Coopetition" in a Bottom-up Federation," Working Papers 2006-10, University of Kentucky, Institute for Federalism and Intergovernmental Relations.
    5. Danuše Nerudová & Veronika Solilová, 2015. "The Impact of the CCCTB Introduction on the Distribution of the Group Tax Bases Across the EU: The Study for the Czech Republic," Prague Economic Papers, Prague University of Economics and Business, vol. 2015(6), pages 621-637.
    6. Ruud De Mooij & Li Liu & Dinar Prihardini, 2021. "An Assessment of Global Formula Apportionment," National Tax Journal, University of Chicago Press, vol. 74(2), pages 431-465.
    7. Martini, Jan-Thomas & Niemann, Rainer & Simons, Dirk, 2014. "Management incentives under formula apportionment: Tax-induced distortions of effort and compensation in a principal-agent setting," arqus Discussion Papers in Quantitative Tax Research 168, arqus - Arbeitskreis Quantitative Steuerlehre.
    8. Dirk Kiesewetter & Tobias Steigenberger & Matthias Stier, 2018. "Can formula apportionment really prevent multinational enterprises from profit shifting? The role of asset valuation, intragroup debt, and leases," Journal of Business Economics, Springer, vol. 88(9), pages 1029-1060, December.
    9. Ortmann, Regina, 2015. "Uncertainty in weighting formulary apportionment factors and its impact on after-tax income of multinational groups," arqus Discussion Papers in Quantitative Tax Research 184, arqus - Arbeitskreis Quantitative Steuerlehre.
    10. Mlčúchová Markéta, 2023. "Formulary apportionment in the European Union—future research agenda," Economics and Business Review, Sciendo, vol. 9(3), pages 124-152, October.
    11. Jan Thomas Martini & Rainer Niemann & Dirk Simons, 2014. "Management Incentives under Formula Apportionment - Tax-Induced Distortions of Effort and Compensation in a Principal-Agent Setting -," CESifo Working Paper Series 4908, CESifo.
    12. Danuše Nerudová & Veronika Solilová, 2015. "Kvantifikace dopadů zavedení společného konsolidovaného základu daně v Evropské unii do celkového základu daně korporací vykazovaného v České republice [Quantification of the Impact on the Total Co," Politická ekonomie, Prague University of Economics and Business, vol. 2015(4), pages 456-473.
    13. Mardan, Mohammed & Stimmelmayr, Michael, 2018. "Tax revenue losses through cross-border loss offset: An insurmountable hurdle for formula apportionment?," European Economic Review, Elsevier, vol. 102(C), pages 188-210.
    14. Martini, Jan Thomas & Niemann, Rainer & Simons, Dirk, 2016. "Tax-induced distortions of effort and compensation in a principal-agent setting," Journal of International Accounting, Auditing and Taxation, Elsevier, vol. 27(C), pages 26-39.
    15. Jochen Hundsdoerfer & Julia Wagner, 2020. "How accurately does the CCCTB apportionment formula allocate profits? An evaluation of the European Commission proposal," Journal of Business Economics, Springer, vol. 90(4), pages 495-536, May.
    16. Ana Agundez-Garcia, 2006. "The Delineation and Apportionment of an EU Consolidated Tax Base for Multi-jurisdictional Corporate Income Taxation: a Review of Issues and Options," Taxation Papers 9, Directorate General Taxation and Customs Union, European Commission, revised Oct 2006.
    17. Regina Ortmann & Erich Pummerer, 2023. "Distortional effects of separate accounting and formula apportionment on factor allocation," Journal of Business Economics, Springer, vol. 93(8), pages 1277-1307, October.
    18. Ortmann, Regina & Sureth, Caren, 2014. "Can the CCCTB alleviate tax discrimination against loss-making European multinational groups?," arqus Discussion Papers in Quantitative Tax Research 165, arqus - Arbeitskreis Quantitative Steuerlehre.
    19. Caterina Liesegang & Marco Runkel, 2009. "Corporate Income Taxation of Multinationals and Fiscal Equalization," CESifo Working Paper Series 2747, CESifo.
    20. James R. Hines, Jr., 1990. "The Transfer Pricing Problem: Where the Profits Are," NBER Working Papers 3538, National Bureau of Economic Research, Inc.
    21. Spengel, Christoph & Wendt, Carsten, 2007. "Harmonisierung der Konzernbesteuerung innerhalb und an den Außengrenzen der Europäischen Union," ZEW Discussion Papers 07-043, ZEW - Leibniz Centre for European Economic Research.

    More about this item

    Keywords

    splitting; formula apportionment; common consolidated corporate tax base; trade tax; German taxation;
    All these keywords.

    JEL classification:

    • H20 - Public Economics - - Taxation, Subsidies, and Revenue - - - General
    • H21 - Public Economics - - Taxation, Subsidies, and Revenue - - - Efficiency; Optimal Taxation
    • H25 - Public Economics - - Taxation, Subsidies, and Revenue - - - Business Taxes and Subsidies
    • H71 - Public Economics - - State and Local Government; Intergovernmental Relations - - - State and Local Taxation, Subsidies, and Revenue
    • K34 - Law and Economics - - Other Substantive Areas of Law - - - Tax Law

    Statistics

    Access and download statistics

    Corrections

    All material on this site has been provided by the respective publishers and authors. You can help correct errors and omissions. When requesting a correction, please mention this item's handle: RePEc:vrs:ceuecj:v:9:y:2022:i:56:p:269-290:n:5. See general information about how to correct material in RePEc.

    If you have authored this item and are not yet registered with RePEc, we encourage you to do it here. This allows to link your profile to this item. It also allows you to accept potential citations to this item that we are uncertain about.

    If CitEc recognized a bibliographic reference but did not link an item in RePEc to it, you can help with this form .

    If you know of missing items citing this one, you can help us creating those links by adding the relevant references in the same way as above, for each refering item. If you are a registered author of this item, you may also want to check the "citations" tab in your RePEc Author Service profile, as there may be some citations waiting for confirmation.

    For technical questions regarding this item, or to correct its authors, title, abstract, bibliographic or download information, contact: Peter Golla (email available below). General contact details of provider: https://www.sciendo.com .

    Please note that corrections may take a couple of weeks to filter through the various RePEc services.

    IDEAS is a RePEc service. RePEc uses bibliographic data supplied by the respective publishers.