Formulary apportionment in international tax law

This thesis explores how global profits of multinational enterprises can be fairly taxed in the age of digitalization and globalization. As value creation and the place of taxation increasingly diverge, transfer pricing based on the arm's length principle reaches its limits. Therefore, the paper analyzes formulary profit apportionment as an alternative method, ultimately assessing it as a pragmatic tool to counter (aggressive) tax planning by global players.