Unitary Taxation of Multinational Enterprises for a Just Allocation of Income: Nigeria as a Case Stu...

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" Unitary Taxation of Multinational Enterprises for a Just Allocation of Income: Nigeria as a Case Study of Africa’s Largest Economies "
Ezenagu, Alexander Christians, Allison

Document Type	:	Latin Dissertation
Language of Document	:	English
Record Number	:	1058825
Doc. No	:	TL57942
Main Entry	:	Ezenagu, Alexander
Title & Author	:	Unitary Taxation of Multinational Enterprises for a Just Allocation of Income: Nigeria as a Case Study of Africa’s Largest Economies\ Ezenagu, AlexanderChristians, Allison
College	:	McGill University (Canada)
Date	:	2019
Degree	:	D.C.L.
student score	:	2019
Note	:	298 p.
Abstract	:	This thesis makes a case for the tax law treatment of multinational enterprises (MNEs) as unitary firms by Nigeria and other African countries under the recently negotiated African Continental Free Trade Agreement (AfCFTA). MNEs strategically exploit their legal structures in order to shift their global profits to low or no tax jurisdictions and away from the countries where their real economic activities occur. Treating MNEs as unitary firms has the potential to significantly curtail these tax avoidance practices. Doing so is particularly important for African countries because they are more dependent on corporate income tax revenues for their national budgetary needs. Most of the corporate tax revenue in these countries must come from foreign-owned firms as these firms dominate the large revenue-generating sectors of their economies, such as oil and gas, mining, agriculture and manufacturing. Two of the main obstacles to the adoption of unitary taxation for MNEs are the corporate legal structures that divide companies across legal jurisdictions, followed closely by the lack of consensus on a workable strategy to implement unitary taxation on a global scale. This thesis answers both of these challenges by providing theoretical and doctrinal support for the unitary approach and by showing the practical aspects and impacts of such adoption through the use of a case study. The thesis accomplishes the first task by revisiting the theories and principles guiding the international tax system and their limitations in today’s global and integrated economic environment. Using Stephen Hymer’s theory of foreign direct investment (FDI) and the single enterprise theory, the thesis demonstrates that treating related entities in MNEs or subsidiaries and their parent companies as unitary firms is both legally and economically coherent despite the traditional view of the corporation as an entity separate from its owners. The thesis then uses Nigeria’s experience in taxing MNEs as a case study to demonstrate how unitary approach would significantly reduce tax avoidance and protect the domestic tax base. It extends its recommendations to other African countries as the AfCFTA comes into effect.
Descriptor	:	African studies
	:	Collaboration
	:	Developing countries--LDCs
	:	International trade
	:	Law
	:	Multinational corporations
	:	Permanent establishment
	:	Profits
	:	Taxation
	:	Transfer pricing
	:	Unitary taxes
Added Entry	:	Christians, Allison
Added Entry	:	McGill University (Canada)