Bibliographic record
Abstract
Abstract This chapter assesses formulary apportionment (FA) as an alternative towards transfer pricing for the allocation of corporate profits among taxing jurisdictions. Although FA has been a relatively old operational notion in subnational corporate taxation, especially in the USA and Canada, it was not generally used in international taxation, other than in theoretical exercises. This is bound to change, as FA is currently the basis of major reform proposals aiming to reregulate the cross-border allocation of taxing powers. FA is usually juxtaposed with transfer pricing and with the arm’s-length principle (ALP). However, the idea of a full or even partial FA goes much further than simply replacing transfer pricing and the ALP: FA challenges the very essence of the allocation rules of the current double tax convention (DTC) network, i.e. source and residence as allocation principles. While formally the constitutive elements of a formula are no nexus, FA modifies the consequences of source and residence in a way that effectively replaces the means used by the source/residence principles and by the DTCs in order to allocate profits. This is done by substituting the world income principle and the attraction force of residence, by profoundly altering the rules deriving from the source principle, and, finally, by rendering the current DTCs obsolete.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.001 | 0.003 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.001 | 0.003 |
| Scholarly communication | 0.004 | 0.004 |
| Open science | 0.001 | 0.002 |
| Research integrity | 0.001 | 0.002 |
| Insufficient payload (model declined to judge) | 0.014 | 0.001 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".