Revisiting Unitary Taxation with Formulary Apportionment Using Public Country-by-Country Reports

In the latest issue of British Tax Review Rodney J. Brown, Bjorn N. Jorgensen and Kerrie Sadiq analyse newly available country-by-country reporting (CbCR) data voluntarily disclosed by 13 firms headquartered or listed in the UK to address two questions.  First, the authors assess the suitability of CbCR data for determining the consolidated pre-tax profit base of MNEs and the subsequent allocation of those profits across jurisdictions.  Secondly, the authors calculate counterfactual jurisdiction level pre-tax profits to determine the extent of any misalignment.