Expansion of the Profit-Split Method: The Wave of the Future

Kadet, Jeffery M.

doi:10.2139/ssrn.2593548

Cited by 1 publication

(2 citation statements)

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“…Another was to shift toward formulary apportionment by strengthening the existing profit‐split method for transfer pricing adjustments (Avi‐Yonah et al . 2009; Kadet 2015). Through the International Centre for Tax and Development I organized a research project to investigate this approach, especially from the perspective of developing countries (Picciotto 2017a).…”

Section: A Decade Of Rapid Policy Changementioning

confidence: 99%

“…One was residence-based worldwide taxation, which would mean extending existing rules on CFCs to a full inclusion system, as originally proposed in the USA in 1962 (Fleming et al 2009). Another was to shift toward formulary apportionment by strengthening the existing profit-split method for transfer pricing adjustments (Avi-Yonah et al 2009;Kadet 2015). Through the International Centre for Tax and Development I organized a research project to investigate this approach, especially from the perspective of developing countries (Picciotto 2017a).…”

Section: The Challenge Of a Paradigm Shiftmentioning

confidence: 99%

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Technocracy in the Era of Twitter: Between intergovernmentalism and supranational technocratic politics in global tax governance

Picciotto

2020

Regulation & Governance

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The international tax system developed as a form of technocratic governance, aimed at facilitating international investment, neglecting provisions for cooperation between national governments for tax enforcement. Its endogenous flaws resulted in its politicization in the 1970s, and again in the 1990s, leading to an increasingly technicized form of global governance. The great financial crisis was even more disruptive and accelerated a shift toward increasingly volatile interactions between the spheres of technocracy and politics. Complex global problems requiring long time-horizons are dealt with by increasingly narrowly focused technical specialists, dominated by corporatized bureaucracies operating in public-private symbiosis; while in the sphere of politics, a wider public seeks simple solutions and mistrusts experts, with good reason given the experience of regulatory failures, often due to the capture of regulation by private interests. Instant communication favors opinion-formers claiming authority, while representative democracy has shifted to "audience representation," opening the way for demagogue leaders, as well as clientelism and corruption. While the financial crisis opened up possibilities for a paradigm shift in international tax governance, the tensions in both the technocratic and political spheres, as well as the growing gap between them, make it hard to achieve a stable and effective outcome.

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Section: A Decade Of Rapid Policy Changementioning

confidence: 99%

Section: The Challenge Of a Paradigm Shiftmentioning

confidence: 99%