Any assessment of the ‘fairness’ of a tax requires making inter-personal comparisons. In the case of a tax on corporate profit, these require looking through the company to investigate the incidence of the tax – which individuals are worse off as a result of the tax. This incidence depends on the properties of the tax – for example, whether it falls on all income or only economic rent, and whether it is levied on a residence, source, or destination basis. Fairness involves consideration of the beneficiaries of the tax revenue, which in an international setting raises the issue of a fair allocation across jurisdictions of rights to tax profit earned by multinational companies.
