TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

Thursday, June 20, 2013

Avi-Yonah: Territoriality: For and Against

Reuven S. Avi-Yonah (Michigan), Territoriality: For and Against:

This article will survey the main arguments for and against territoriality and conclude that it is the wrong way to go in the short run, but can perhaps be adopted in the medium to long run in conjunction with more fundamental international tax reform. The main reason that territoriality should not be adopted now is that the OECD may be about to recommend worldwide consolidation for all its members as part of the Base Erosion and Profit Shifting (BEPS) project, and if the OECD does that, all of the standard arguments in favor of territoriality and against abolishing deferral disappear.

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