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Session objective: To show how tax apportionment formulae can have a large impact on how much corporation tax a country receives.

Learning objective(s):

  • Understand the concept of profit apportionment
  • Begin to question why the OECD uses particular formulae in determining how much corporate tax is paid to a country.

Group size: 24

Time required: 45 minutes

Materials required:

  • Tokens to represent profits
  • Masking tape on the floor, separating the room into three sections. Put a sheet in each section named; headquarters, employees, sales.

Methodology:

  1. Split the large group into two and give them the instructions.
  2. Tell them to think of a company that has its headquarters in one country, manufactures in another (or many others), and sells in countries other than or in addition to where it is headquartered. Give them 5-7 minutes to decide on a hypothetical or real-life company, and to create a short pitch to describe the activities of the company.
  3. Ask group B to sit to the side while you are working with group A.
  4. Ask group A to tell the whole group what their company does to make its money.
  5. Instruct all members of group A to go to Section 1: Headquarters.
  6. Give them all the tokens.
  7. Ask group B what is happening in this scenario.
  8. Switch the groups and ask group B to tell the whole group what their company does.
  9. Ask for one third of the group to go to Section 2: Employees and Section 3: Sales.
  10. Distribute the tokens three ways equally.
  11. Ask group A what is happening. 
  12. Discuss with the group that what you have all just shown is a simplified simulation of two formulae for apportioning profits. Discuss with the group what the implications would be of each formula for different countries around the world.
  13. Ask, what type of formula do they think would be most fair?
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