Territoriality: For and Against

Reuven S. Avi-Yonah

University of Michigan Law School

April 25, 2013

U of Michigan Public Law Research Paper No. 329
U of Michigan Law & Econ Research Paper No. 13-008

This article will survey the main arguments for and against territoriality and conclude that it is the wrong way to go in the short run, but can perhaps be adopted in the medium to long run in conjunction with more fundamental international tax reform. The main reason that territoriality should not be adopted now is that the OECD may be about to recommend worldwide consolidation for all its members as part of the Base Erosion and Profit Shifting (BEPS) project, and if the OECD does that, all of the standard arguments in favor of territoriality and against abolishing deferral disappear.

Number of Pages in PDF File: 6

Keywords: Territoriality

JEL Classification: H25

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Date posted: April 27, 2013 ; Last revised: June 22, 2013

Suggested Citation

Avi-Yonah, Reuven S., Territoriality: For and Against (April 25, 2013). U of Michigan Public Law Research Paper No. 329; U of Michigan Law & Econ Research Paper No. 13-008. Available at SSRN: http://ssrn.com/abstract=2256580 or http://dx.doi.org/10.2139/ssrn.2256580

Contact Information

Reuven S. Avi-Yonah (Contact Author)
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
734-647-4033 (Phone)

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