Formula apportionment appeals to governments with high corporate tax rates because it would increase their revenues, while jurisdictions with pro-growth policies would lose out.

FORBES: New OECD Report Calls For Crippling New Corporate Tax Rules

Formula apportionment is attractive to governments that have punitive tax regimes, and it would be a blow to nations with more sensible low-tax systems.

FORBES: Targeting Multinationals, the OECD Launches New Scheme to Boost the Tax Burden on Business

If a formula apportionment system had been in place, the world would have been left with much higher tax rates, and thus less investment and economic growth.

FORBES: Targeting Multinationals, the OECD Launches New Scheme to Boost the Tax Burden on Business