I’m conscious that I’ve let this lie for a couple of months, but although I haven’t been posting about it I have been working on Unitary Tax quite a bit.
My original intention was to put together a simple toy model of Unitary Tax to play around with various concepts. I have such a model, but it’s too simple to do anything useful at this stage and there are such a lot of questions to be asked and answered that I’ve diverted myself into looking at those first. They all seem to interconnect, so it’s hard to make progress on say the Sales factor without also looking at Assets and how that affects Permanent Establishment, and so on.
I’ve also been sidetracked into reading up what other people have been saying about UT and Fomulary Apportionment. What I’ve concluded is that I need to pull all this together into a single set of principles before I can start sullying it with numbers. So I’m drafting up a paper which will hopefully give me a coherent theoretical framework, and then I can return to the numbers.
It will probably take a while. Not least because people are writing more papers while I’m reading the existing ones – this tortoise will take some catching… 🙂