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Whether or not this apportionment of profits complies with transfer-pricing rules, it is "not consistent with a commonsense understanding of where the locus of Microsoft's economic activity…is occurring," said Mr Shay.
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These groups argue that the current system is so open to abuse it should be replaced with a new model – known as unitary taxation – which they claim would better link the apportionment of taxable profits by multinationals to the territories in which economic activities occur.
Some FTC member groups want to explore whether the many hundreds of existing bilateral tax treaties that facilitate global trade should be torn up and replaced with a new model – known as unitary taxation – which they claim would better link the apportionment of taxable profits by multinationals to the territories in which economic activities occur.
Allocation of profits.
But what of profits?
To say nothing of profits.
No sign of profits yet.
That apportionment of blame wasn't strictly accurate.
Allocation of resources, apportionment of productive assets among different uses.
THE WITNESS: An apportionment of sixty-six into whatever the licensing fee was.
For the time being the apportionment of blame can be left to the historians.
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