Comparison of European, Canadian and U.S. Formula Apportionment on Real Data

The harmonization of the tax regime of EU Member States represents one possible way to intensify their economic integration. Tax harmonization by a Common Consolidated Corporate Tax Base constitutes a similar system to which has been used in Canada, USA or Switzerland since the last century. The present paper describes the principles of formulas apportionment which are used in Canada and the USA and proves different distribution of the tax base in comparison with the formula apportionment as published in the proposal to the Council Directive on a Common Consolidated Corporate Tax Base of 16 March 2011.