| Abstract |
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[eng] This paper investigates a reform of the taxation of multijurisdictional enterprises, consisting in a move from Separate Accounting to Formulary Apportionment. The study is conducted within a framework which embodies the existence of transfer pricing strategies and other tax-shifting opportunities on the one hand, and the risk of incurring losses and the possibility of interjurisdictional loss-offset under both Separate Accounting and Formulary Apportionment mechanisms on the other hand. Findings are summarised in a series of propositions on both the strategic behaviour of multijurisdictional enterprises and that of tax authorities. |
