An Assessment of Global Formula Apportionment

Ruud De Mooij, Li Liu and Dinar Prihardini

National Tax Journal, 2021, vol. 74, issue 2, 431 - 465

Abstract: Global formula apportionment as a way to attribute taxable profits of multinationals across jurisdictions is receiving increased attention in recent debates on the future of the international tax framework. This paper exploits different data sets to assess the direct revenue implications of formula apportionment, both globally and for individual countries, under alternative formulas. The aggregate tax base is estimated to fall by approximately 10 percent due to cross-border loss consolidation. The associated loss in global corporate income tax revenue is smaller, though, between 5 and 8 percent depending on the formula, as profit shifting is mitigated. The distributional effects across countries are found to be large, reflecting major discrepancies between where profits are currently attributed and where factors of production are located or sales take place. The largest losses appear in low-tax jurisdictions and investment hubs (i.e., countries with a disproportionate ratio of foreign direct investment to gross domestic product), while several large advanced countries are likely to gain. Developing countries most likely gain if employment receives a large weight in the formula; they also tend to benefit, on average, from a formula based on sales by destination. The paper also reviews the literature on dynamic effects of formula apportionment, which may significantly alter the results based on static analysis.

Date: 2021
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Working Paper: An Assessment of Global Formula Apportionment (2019)
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