School of Law

Research Student: Fabricio Costa Resende de Campos

A Model for Corporate Income Tax: Unitary Taxation of Corporate Groups

Photo of Fabricio Costa Resende de Campos

The economic role of multinational corporations in world trade has increased dramatically over the past 20 years. This partly reflects the enlarging integration of national economies and technological progress. There is evidence that the intragroup trade is growing steadily and has accounts for more than 30 percent of all international transactions (UN, 2013).

The significant volume of global trade made by international transfers of goods, services, capital (as money) and intangible (such as intellectual property) within the same business group increases tax issues for tax authorities and also to those companies in each country.

Share of intra-group economic activity consists of managing the tax burden, transferring income and expenses between the components of the business group for the group companies based in countries with low tax or no tax on income (Harris, 1993; K. Klassen, Lang, and Wolfson, 1993; Weichenrieder, 1996; Avi-yonah, Clausing, & Durst, 2009; OECD, 2013; Devereux and Feria, 2014). Recently, the media has highlighted examples of intra-group operations which lead to a significant reduction in the overall tax burden on businesses, for example Google, eBay, Starbucks and Apple (Bergin 2012; Milne 2012). In this scenario, corporate Income Tax has an important role as an inductor of the investments to be carried out by corporate groups.

Some economic models were developed in order to indicate the optimal option to transfer profits from one company to another, analysing the taxation in country of residence of the parent company and the country of residence of the subsidiary; the repatriation costs of the subsidiary's profits and the possibility of reinvestment of profits abroad (Hartman, 1985; Sinn, 1993; Altshuler and Grubert, 2003; Klassen, Laplante and Carnaghan, 2013).

This proposal, from the point of view of international tax law, accounting and economic sciences doctrine aims to contribute to previous literature by implementing a new model of income taxation on a worldwide basis, through the consolidated balance sheet.


I graduated in Law at Pontifical Catholic University of Minas Gerais and started my career as a tax lawyer in Brazil.

In view to improve my academic and professional baggage, I graduated in Accounting at Pontifical Catholic University of Sao Paulo. Accounting and Economic theories enable a better understanding of tax law and an interdisciplinary vision.

Other complementary knowledge was obtained through my MSc in Accounting, which provided courses in International Economics, Public Economics and Econometrics. Those classes enabled me to receive a high-quality interdisciplinary training unusual in academic research.

What motivated me to undertake PhD study?

To improve my scientific background and expertise and do good quality research in tax law.

What makes me passionate about my subject?

Tax law is a multidisciplinary area and, to provide a good quality research, necessarily, people involved in this matter have to strengthen their knowledge of different scientific subjects, such accounting and economics.

What are my plans once I have completed my PhD?

To dedicate fully to tax research.

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