Territoriality: For and Against

6 Pages Posted: 27 Apr 2013 Last revised: 22 Jun 2013

Date Written: April 25, 2013


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.

Keywords: Territoriality

JEL Classification: H25

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: https://ssrn.com/abstract=2256580 or http://dx.doi.org/10.2139/ssrn.2256580

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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