The Interaction Of Federal And Provincial Taxes On Businesses

This paper provides an analysis of the ways in which the interaction between federal and provincial taxes on businesses can create distortions in the levels and types of taxation and identifies ways in which these distortions can be minimized or even eliminated.

Since its Company Tax Communication of 2001, the European Commission has been promoting a comprehensive harmonization of corporation taxes within the Internal Market on the basis of consolidation and formulary apportionment of the profits of cross-border enterprises, both in the form of a Home State Taxation (HST) and of the Common Consolidated Corporate Tax Base. This study assesses whether this approach represents a viable alternative to the arm's length standard currently applied in international tax law. The study comprises four parts. First, a theoretical concept of formulary apportionment is presented, followed by an evaluation of the practical experiences of four jurisdictions (United States, Canada, Switzerland and Germany) with formulary apportionment at the subnational level. Next, a proposal for harmonization on the basis of consolidation and apportionment is developed, and the book concludes with an overall analysis of the merits and drawbacks of the proposed model for harmonization.

In this new edition of Uneasy Partnership, Geoffrey Hale examines the interdependent relationship between Canadian governments and businesses, considering governments’ multiple roles in the economy and their implications for the business environment. Hale provides an overview of the historical dimensions of Canada’s political economy and relations between government and business. Readers are invited to consider topics such as corporate power, the implications of Canada's economic structure, regional economic differences, the cross-cutting effects of globalization, and the role of interest groups in political and policy processes. In a thoughtful and well-researched style, Hale lays out how the partnership between business and government in Canada is an uneasy one—and one whose capacity to adapt to ongoing change is essential in an uncertain world.

Canada: State of the Federation, 1999–2000 identifies and explains major threads in Canadian fiscal federalism. Set against the cacophony over domineering and arrogant centralization from supporters of Quebec sovereignty/session on the one hand, and fears that excessive decentralization is fuelling an obsessively neo-liberal agenda on the other, these essays replace much of this heat with new light. The authors begin with an examination of recent developments in the theoretical literature surrounding fiscal federalism. They then examine some of the major issues facing the federation – Is there a vertical imbalance between federal and provincial governments? Does Ottawa collect more revenues than are needed relative to its spending responsibilities while the provinces are under-funded? How do federal-provincial struggles over money and jurisdictional power affect local government or the para-public sector, emerging aboriginal governments, and citizens? Federal government actions in 1999 suggest that Ottawa has not lost all of its interest in social outcomes. It is, however, seeking to influence the well-being of citizens by transferring money to them directly rather than through transfers to provinces. The authors suggest that if this trend continues the approach to the millennium will be seen as a watershed in public policy, given that current trends in Canadian fiscal federalism are as much about re-balancing the federation as they are about decentralization.

The Allocation of Multinational Business Income: Reassessing the Formulary Apportionment Option Edited by Richard Krever & François Vaillancourt Although arm’s length methodology continues to prevail in international taxation policy, it has long been replaced by the formulary apportionment method at the subnational level in a few federal countries. Its use is planned for international profit allocation as an element of the European Union’s CCCTB proposals. In this timely book – a global guide to formulary apportionment, both as it exists in practice and how it might function internationally – a knowledgeable group of contributors from Australia, Canada, the United Kingdom and the United States, address this actively debated topic, both in respect of its technical aspects and its promise as a global response to the avoidance, distortions, and unfairness of current allocation systems. Drawing on a wealth of literature considering formulary apportionment in the international sphere and considering decades of experience with the system in the states and provinces of the United States and Canada, the contributors explicate and examine such pertinent issues as the following: the debate about what factors should be used to allocate profits under a formulary apportionment system and experience in jurisdictions using formulary apportionment; application of formulary apportionment in specific sectors such as digital enterprises and the banking industry; the political economy of establishing and maintaining a successful formulary apportionment regime; formulary apportionment proposals for Europe; the role of traditional tax criteria such as economic efficiency, fairness, ease of administration, and robustness to avoidance and incentive compatibility; determining which parts of a multinational group are included in a formulary apportionment unit; and whether innovative profit-split methodologies such as those developed by China are shifting traditional arm’s length methods to a quasi-formulary apportionment system. Providing a comprehensive understanding of all aspects of the formulary apportionment option, this state of the art summary of history, current practice, proposals and prospects in the ongoing debate over arm’s length versus formulary apportionment methodologies will be welcomed by practitioners, policy-makers, and academics concerned with international taxation, all of whom will gain an understanding of the case put forward by proponents for adoption of formulary apportionment in Europe and globally and the counter-arguments they face. Readers will acquire a better understanding of the implications of formulary apportionment and its central role in the current debate about the future of international taxation rules. “...providing (sic) all the intellectual ammunition needed to carefully re-examine one of the ideas traditionally considered as apocryphal by the OECD and to a significant portion of the tax professional community...readers of this book will come away not only with a renewed understanding of the multiple facets of formulary apportionment, but also of some of the fundamental pressure points in the international tax system. Accordingly, it is a welcome and timely addition to the literature. ” Dr. Stjepan Gadžo, Assistant Professor at University of Rijeka, Faculty of Law / British Tax Review 2021, Issue 2, p243-246

This 1997 edition of OECD's periodic surveys of Canada's economy examines recent economic developments, policies and prospects. It includes a special feature on the tax system.