3.7 Global Formulary Apportionment
IRBM does not accept methods based on global formulary apportionment on the basis that they are arbitrary and could not reliably approximate arm's length conditions. Global formulary apportionment refers to a method which uses a predetermined and mechanistic formula normally based on a combination of costs, assets, payroll and sales to allocate the global profits of an MNE group among associated enterprises in different countries