Abstract

http://ssrn.com/abstract=2351920
 


 



Unitary Taxation and International Tax Rules


Reuven S. Avi-Yonah


University of Michigan Law School

Zachee Pouga Tinhaga


University of Michigan Law School

November 8, 2013

U of Michigan Public Law Research Paper No. 369
U of Michigan Law & Econ Research Paper No. 13-020

Abstract:     
Any proposal to adopt Unitary Taxation (UT) of multinationals has to contend with whether such taxation is compatible with existing international tax rules and in particular with the bilateral tax treaty network. Indeed, some researchers have argued that the separate accounting (SA) method and the arm’s length standard are so embodied in the treaties that they form part of customary international law and are binding even in the absence of a treaty. In this paper we will argue that UT can be compatible with most of the existing tax treaties, and that developing countries in particular can implement it in most cases with or without a tax treaty.

Number of Pages in PDF File: 35

Keywords: unitary taxation, tax treaties

JEL Classification: H26

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Date posted: November 8, 2013 ; Last revised: December 18, 2013

Suggested Citation

Avi-Yonah, Reuven S. and Tinhaga, Zachee Pouga, Unitary Taxation and International Tax Rules (November 8, 2013). U of Michigan Public Law Research Paper No. 369; U of Michigan Law & Econ Research Paper No. 13-020. Available at SSRN: http://ssrn.com/abstract=2351920 or http://dx.doi.org/10.2139/ssrn.2351920

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)
Zachee Pouga Tinhaga
University of Michigan Law School ( email )
625 South State Street
Ann Arbor, MI 48109-1215
United States
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