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A Common Corporate Tax Base For Europe
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Book Synopsis European Union Corporate Tax Law by : Christiana HJI Panayi
Download or read book European Union Corporate Tax Law written by Christiana HJI Panayi and published by Cambridge University Press. This book was released on 2013-05-09 with total page 413 pages. Available in PDF, EPUB and Kindle. Book excerpt: How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies and permanent establishments. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted.
Book Synopsis Corporate Income Tax Harmonization in the European Union by : D. Pîrvu
Download or read book Corporate Income Tax Harmonization in the European Union written by D. Pîrvu and published by Springer. This book was released on 2012-08-13 with total page 386 pages. Available in PDF, EPUB and Kindle. Book excerpt: Through the arguments for corporate tax harmonization in the EU and describing the current stage of this process, the legislative rules which are insufficient to solve the many problems implied by the proper functioning of the Single Market, are revealed. The book also exposes the issues involved in the consolidation of the corporate tax base.
Book Synopsis Corporate Taxation, Group Debt Funding and Base Erosion by : Gianluigi Bizioli
Download or read book Corporate Taxation, Group Debt Funding and Base Erosion written by Gianluigi Bizioli and published by Kluwer Law International. This book was released on 2020-02-07 with total page 280 pages. Available in PDF, EPUB and Kindle. Book excerpt: The EU's Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD's Base Erosion and Profit Sharing project (BEPS) and the EU's Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States--Germany, Italy, Spain and The Netherlands--as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.
Book Synopsis The EU Common Consolidated Corporate Tax Base by : Dennis Weber
Download or read book The EU Common Consolidated Corporate Tax Base written by Dennis Weber and published by Kluwer Law International. This book was released on 2018 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Some introductory remarks on the relaunched CCTB/CCCTB proposals from a policy perspective / Jan van de Streek -- Principles and characteristics of CCTB after the relaunch / Ronald Russo -- Depreciation rules and roll-over relief under the proposed CCTB directive / Hein Vermeulen -- Allowance for growth and investment / Stefano Grilli -- The R&D tax incentives / Paolo Arginelli -- The participation exemption / Marjaana Helminen -- Cross-border loss relief under the proposed CCTB directive / Bruno da Silva -- The arm's length standard : a blind spot in the CC(C)TB proposals / Daniel S. Smit -- Exit tax / Rita Szudoczky -- Tax avoidance and the return of CC(C)TB / Frans Vanistendael -- Interest limiation rule / Ruben Martini -- The switch-over clause / Daniel Gutmann -- The controlled foreign company regime / Werner Haslehner -- The GAAR / Markus Seiler -- Consolidation within the CCCTB / Fabian Munsterman -- Tax competition within the European Union revisited : is the relaunched CCCTB a solution? / Maarten F. de Wilde -- Procedural and administrative aspects of the CCCTB / Sjoerd Douma.
Book Synopsis Combating Tax Avoidance in the EU by : José Manuel Almudí Cid
Download or read book Combating Tax Avoidance in the EU written by José Manuel Almudí Cid and published by Kluwer Law International B.V.. This book was released on 2018-12-20 with total page 880 pages. Available in PDF, EPUB and Kindle. Book excerpt: Following each Member State's need to rebuild a strong and stable economy after the 2007 financial crisis, the European Union (EU) has developed a robust new transparency framework with binding anti-abuse measures and stronger instruments to challenge external threats of base erosion. This is the first and only book to provide a complete detailed analysis of the Anti-Tax Avoidance Package and other recent and ongoing European actions taken in direct taxation. With contributions from both prominent tax academics and Spain's delegates to the European meetings where these rules are debated and promulgated, the book covers such issues and topics as the following: – the development of the EU Strategy towards Aggressive Tax Planning; – recent tax-related jurisprudence of the European Court of Justice; – the Anti-Tax Avoidance Directive; – tax treaties and non-tax treaties with tax consequences both between Member States and between Member States and third countries; – code of conduct for business taxation; – automatic exchange of information; – country-by-country reporting; – arbitration in tax matters; – external strategy for effective taxation regarding non-EU countries; – competition and state aid developments in direct taxation; – the Common Consolidated Tax Base; and – digital significant presence and permanent establishment. As the EU pursues its ambitious tax agenda, taxation's contribution to EU growth and competitiveness and its part in relations with the rest of the world will come into ever clearer focus. In addition to its insights into these trends, the book's unparalleled practical information and analysis will be of great value to tax practitioners dealing with investment analysis, tax planning schemes, and other features of the current international tax landscape.
Book Synopsis Double Taxation Within the European Union by : Alexander Rust
Download or read book Double Taxation Within the European Union written by Alexander Rust and published by . This book was released on 2011 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: Despite the conclusion of tax treaties and despite the enactment of several directives, double taxation continues to occur within the EU, causing severe obstacles for cross-border trade, for the provision of services and capital, and for the free movement of persons. This book collects the expert analysis and recommendations on the following issues: the reasons for the existence (and persistence) of juridical and economic double taxation; double burdens in criminal law; constitutional limits for double taxation; the Lisbon Treaty's abolition of Article 293 EC, which had required Member States to conclude tax treaties in order to abolish double taxation; whether double taxation can be avoided by the application of the four freedoms; prospects for an EU-wide multilateral tax treaty; the proposed Common Consolidated Corporate Tax Base; and use of arbitration clauses in tax treaties.
Download or read book CCCTB written by Dennis Weber and published by Kluwer Law International B.V.. This book was released on 2012-05-10 with total page 441 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Commission’s proposed Common Consolidated Corporate Tax Base (CCCTB) is the most ambitious project in the history of direct taxation within the EU. While retaining the right of Member States to set their own corporate tax rate, the proposed system allows for a ‘one-stop shop’ for filing tax returns and consolidating prof its and losses across the EU. In this book – the first to offer guidance to practitioners whose work will be affected by these new developments – 19 prominent representatives of the business community, tax consultancy, academic taxation scholarship and tax administration discuss the proposed system’s rationale, structure and uncertainties, ranging from very technical aspects, to the wording of the proposal, to political considerations. These topics include the following: eligibility; formation of a group; the concept of ‘permanent establishment’; foreign tax credits; ‘dual resident’ companies; consequences of entering and leaving; depreciation of fixed assets; repackaged asset transfers; appeals procedure; disagreements among Member States; subsidiarity and the ‘yellow card procedure’; international aspects and tax treaties; sharing mechanism and transfer pricing; and anti-abuse rules. The discussion raises numerous issues likely to lead to future amendments, and for this reason, along with its practical value in developing an understanding of the proposed system’s specific effects, the book will be welcomed by tax consultants and lawyers worldwide, corporate tax advisers, European tax authorities and tax researchers and academics.
Book Synopsis A Guide to the Anti-Tax Avoidance Directive by : Werner Haslehner
Download or read book A Guide to the Anti-Tax Avoidance Directive written by Werner Haslehner and published by Edward Elgar Publishing. This book was released on 2020-06-26 with total page 340 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a concise, practical guide to the European Union’s Anti-Tax Avoidance Directive (ATAD). Presenting unique insights into the ATAD’s five specific anti-avoidance rules, its chapters explain the background of those rules, the directive’s interactions with relevant jurisprudence, and the challenges posed to the ATAD’s interpretation and implementation in domestic law.
Book Synopsis Harmful Tax Competition An Emerging Global Issue by : OECD
Download or read book Harmful Tax Competition An Emerging Global Issue written by OECD and published by OECD Publishing. This book was released on 1998-05-19 with total page 82 pages. Available in PDF, EPUB and Kindle. Book excerpt: Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Book Synopsis Corporate Tax Policy and Incorporation in the EU by : Ruud A. de Mooij
Download or read book Corporate Tax Policy and Incorporation in the EU written by Ruud A. de Mooij and published by . This book was released on 2008 with total page 44 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Book Synopsis A Common Consolidated Corporate Tax Base for Europe – Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa by : Wolfgang Schön
Download or read book A Common Consolidated Corporate Tax Base for Europe – Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2008-04-24 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt: Preface This book contains the proceedings of the International Tax Conference on the c- th th mon consolidated corporate tax base (CCCTB) that was held in Berlin on 15 – 16 may 2007. The conference was jointly organised by the German Federal Ministry of Finance, the Centre for European Economic Research (ZEW), Mannheim, and the Max Planck Institute (MPI) for Intellectual Property, Competition and Tax Law, Munich. More than 250 participants from all over Europe and other regions, scholars, politicians, business people and tax administrators, discussed the Eu- pean Commission’s proposal to establish a CCCTB. Three panels of tax experts evaluated the common tax base with respect to structural elements, consolidation, allocation, international aspects and administration. The conference made clear that the CCCTB has the potential to overcome some of the most intriguing problems of corporate income taxation within the Common Market. Common tax accounting rules substantially reduce compliance and administrative costs. Consolidation of a group’s profits and losses effects cro- border loss compensation which removes a major tax obstacle for European cro- border investment. At the same time, tax planning with respect to financing and transfer pricing is pushed back within the European Union. Moreover, as far as the CCCTB applies, member states are able to remove tax provisions that are targeted at cross border tax evasion and that might be challenged by the jurisdiction of the Eu- pean Court of Justice.
Book Synopsis Common Corporate Tax Base in the EU by : Christoph Spengel
Download or read book Common Corporate Tax Base in the EU written by Christoph Spengel and published by Springer Science & Business Media. This book was released on 2011-10-12 with total page 186 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Commission envisages putting forward a proposal for a tax reform that would allow improving the efficiency and simplicity of the corporate income tax systems. This report assesses the impact of a Common Corporate Tax Base (CCTB) on the size of the corporate tax bases of EU companies. The results of the report shall help to evaluate the economic consequences of the introduction of a harmonised set of tax accounting rules. The estimates are based on the European Tax Analyzer with data from the year 2006 and apply options specified by the Commission’s Steering Group.
Download or read book European Tax Law written by Ben Terra and published by Springer. This book was released on 1997-08-27 with total page 400 pages. Available in PDF, EPUB and Kindle. Book excerpt: Although a genuine European tax hardly exists as such, the EC policy of aligning national taxes and tax policies insofar as is necessary for a common market affects taxation and tax law in all Member States. European Tax Law systematically surveys the EC tax rules that arise from this policy and their implications. It provides a detailed discussion of European integration and Community tax harmonisation policy, with practical analysis of all the relevant Community tax rules, in force and pending. The book's clear, straightforward coverage includes: tax measures already taken at the Community level and their legal basis; the current state of positive harmonisation as manifested in EC regulations and directives; the effect of 'negative integration' (such as prohibition of discrimination) that limits Member States' freedom to arrange their own national tax systems; the surprising effect of national habits and couleur locale ; and the consequences of general (non-fiscal) Community law for national tax laws as it emerges in the case law of the European Court of Justice. European Tax Law includes an extensive index and a table of cases for easy access to information. Practitioners, academics, and advanced students of tax law and EC law will value the lucid, ordered, and comprehensive coverage of this resource.
Book Synopsis International Company Taxation and Tax Planning by : Dieter Endres
Download or read book International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.
Book Synopsis The EU Common Consolidated Corporate Tax Base by : Dennis Weber
Download or read book The EU Common Consolidated Corporate Tax Base written by Dennis Weber and published by Kluwer Law International B.V.. This book was released on 2016-04-24 with total page 210 pages. Available in PDF, EPUB and Kindle. Book excerpt: In October 2016, the European Commission relaunched its plan to harmonize national income tax systems via the Common Consolidated Corporate Tax Base (CCCTB), perhaps the most ambitious reform of EU tax law ever attempted. This timely book offers an early analysis of this important proposal and its implications, covering issues such as the project’s scope and main elements, international considerations, the relationship with OECD’s base erosion and profit shifting (BEPS) initiative, consolidation, and anti-abuse rules. With carefully selected papers first presented at a January 2017 conference hosted by the Amsterdam Centre for Tax Law, this volume focuses on such topics and issues as the following: – ways in which the proposed CCCTB is designed to preserve the competence of Member States to set their own tax rates; – reduction of the administrative burden for multinational companies; – incentives for research and development; – automatic cross-border relief within the EU; – detailed analysis of the proposal’s formula apportionment regime; – proposed new controlled foreign company (CFC) rules; and – interest limitation rule. Because of the commitment of many Member States to keep their corporate income tax systems competitive on a stand-alone basis, the proposed CCCTB is enormously controversial. This book provides authoritative insights into problems likely to arise and discusses the prospects of how the proposal is likely to be implemented. Thus, this book proves to be of immeasurable value to taxation policymakers, practitioners, and academics.
Book Synopsis Foreign Ownership and Corporate Income Taxation by : Harry Huizinga
Download or read book Foreign Ownership and Corporate Income Taxation written by Harry Huizinga and published by . This book was released on 2003 with total page 64 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recoge : 1. Introduction. - 2. Previous literature. - 3. The data. - 4. The estimation. - 5. Empirical results. - 6. Conclusions.
Book Synopsis Tax Revenues in the European Union by : Giuseppe Carone
Download or read book Tax Revenues in the European Union written by Giuseppe Carone and published by . This book was released on 2007 with total page 48 pages. Available in PDF, EPUB and Kindle. Book excerpt: Recoge: 1. Introduction - 2. Structure and taxation in the European Union - 3. Recent trends and reforms - 4. The challenges ahead - 5. Conclusions.
