The Promise of Non-arm’s Length Practices: Is the Destination-Based Cash Flow Tax or Unitary Taxation the Panacea of Which Developing Countries Are in Search?

Abstract

AbstractThe issues developing countries face when implementing the arm’s length standard are well known. As a result, the time seems opportune for an alternative paradigm. The unitary taxation system has received considerable attention and comment over the last few years as such an alternative. Some have heralded it as the answer to the many problems brought about by the arm’s length standard. Moreover, some suggest that the destination-based cash flow taxation system is the panacea to the present problems in international tax arising from the prevailing approach to the taxation of global affiliated companies. This article tests whether the destination-based cash flow tax and unitary taxation system continue to hold promise when applied in an African context.