Formulary apportionment in international tax law

An allocation method for the age of globalization and digitalization

By (author) Michael Mautsch

Book cover: Formulary apportionment in international tax law

Extent: 205 pages

Publisher: Duncker & Humblot

Series: Schriften zum Steuerrecht

Series volume number: 210

Language: English

Paperback (Published)

(August 2026)

ISBN: 9783428198382

6.18 x 9.17 inches

Price: $89.00

Out of stock

This thesis explores how global profits of multinational enterprises can be fairly taxed in the age of digitalization and globalization. As value creation and the place of taxation increasingly diverge, transfer pricing based on the arm’s length principle reaches its limits. Therefore, the paper analyzes formulary profit apportionment as an alternative method, ultimately assessing it as a pragmatic tool to counter (aggressive) tax planning by global players.


This thesis explores how global profits of multinational enterprises can be fairly taxed in the age of digitalization and globalization. As value creation and the place of taxation increasingly diverge, transfer pricing based on the arm’s length principle reaches its limits. Therefore, the paper analyzes formulary profit apportionment as an alternative method, ultimately assessing it as a pragmatic tool to counter (aggressive) tax planning by global players.

1. Introduction

2. The basic problem of BEPS

3. Foundations of international taxation

4. Two methods of allocating income among jurisdictions – formulary apportionment and transfer pricing

5. Formulary apportionment systems: Some examples from national, European and international tax law

6. Overview of existing proposals to overcome shortcomings

7. »Reform proposal«

8. Conclusion

  • By (author) Michael Mautsch