ICTD Working Paper 35

This paper analyses whether a global unitary taxation approach to corporate income tax (CIT) can improve the ability of governments to design and administer efficient and effective tax and royalty policies for the extractive industries. Drawing upon experience with unitary approaches to corporate income taxation of the extractive sectors in subnational taxation systems of the United States (US) and Canada, this paper suggests that a unitary CIT should not be used in isolation, or be employed as the dominant source of revenue from the extractive sector. Instead, because of its informational and risk-aligning advantages, a unitary CIT may be best used in combination with other rent/profit-related levies on the extractive sector. At the same time the rent/profit-related levies may be assessed on a more limited base, such as source jurisdiction, in order to alleviate source entitlement concerns. Within this context a unitary CIT is recommended, because it enables more effective design and administration of all taxes in the extractive industries sector.


Erika Dayle Siu

Sol Picciotto

Sol is an emeritus professor at Lancaster University, a Senior Adviser of the Tax Justice Network, coordinator of the BEPS Monitoring Group, and a member of the UN Tax Committee's subcommittee on dispute resolution. As a Senior Fellow of the ICTD, his research focuses on the taxation of transnational corporations with special reference to developing countries.

Jack Mintz

Akilagpa Sawyerr

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