Neutralities and non-neutralities in international corporate taxation : an evaluation of possible and recent moves

Motivated by the move of Germany away from imputation and the objective announced by the EU Commission to provide EU businesses with a consolidated corporate tax base for their EU-wide activities, this paper proposes an analysis of the properties of alternative systems for taxing multinational enterprises, first under separate tax base and then under consolidation with apportionment. In particular it investigates whether those tax systems can become perfectly integrated, i.e. neutral with respect to financial, organisational and location decisions of a multijurisdictional firm; the transfer pricing issue also deserves a special attention.