Ec Free Movement Of Capital Corporate Income Taxation And Third Countries

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EC Free Movement of Capital, Corporate Income Taxation and Third Countries

Author : B.J. Kiekebeld
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041130349
Total Pages : 172 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis EC Free Movement of Capital, Corporate Income Taxation and Third Countries by : B.J. Kiekebeld

Download or read book EC Free Movement of Capital, Corporate Income Taxation and Third Countries written by B.J. Kiekebeld and published by Kluwer Law International B.V.. This book was released on 2008-02-20 with total page 172 pages. Available in PDF, EPUB and Kindle. Book excerpt: Free movement of capital is at the heart of the Single Market and is one of its “four freedoms”. It enables integrated, open, competitive and efficient European financial markets and services. For citizens it means the ability to perform many operations abroad, as diverse as opening bank accounts, buying shares in non-domestic companies, investing where the best return is, and purchasing real estate. For companies it principally means being able to invest in and own other European companies and take an active part in their management. With all its benefits, the free movement of capital brings with it an array of thorny issues. This timely work explores several of the most critical, focusing on the practical ability of national law to satisfy the relevant EU requirements

EU Freedoms, Non-EU Countries and Company Taxation

Author : D.S. Smit
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041140743
Total Pages : 822 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis EU Freedoms, Non-EU Countries and Company Taxation by : D.S. Smit

Download or read book EU Freedoms, Non-EU Countries and Company Taxation written by D.S. Smit and published by Kluwer Law International B.V.. This book was released on 2012-06-01 with total page 822 pages. Available in PDF, EPUB and Kindle. Book excerpt: In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.

The EU and Third Countries

Author : Michael Lang
Publisher :
ISBN 13 : 9783707309324
Total Pages : 1072 pages
Book Rating : 4.3/5 (93 download)

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Book Synopsis The EU and Third Countries by : Michael Lang

Download or read book The EU and Third Countries written by Michael Lang and published by . This book was released on 2007 with total page 1072 pages. Available in PDF, EPUB and Kindle. Book excerpt:

European Union Corporate Tax Law

Author : Christiana H. J. I. Panayi
Publisher : Cambridge University Press
ISBN 13 : 1108983480
Total Pages : 397 pages
Book Rating : 4.1/5 (89 download)

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Book Synopsis European Union Corporate Tax Law by : Christiana H. J. I. Panayi

Download or read book European Union Corporate Tax Law written by Christiana H. J. I. Panayi and published by Cambridge University Press. This book was released on 2021-06-17 with total page 397 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 book 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. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.

Landmark Decisions of the ECJ in Direct Taxation

Author : Werner Haslehner
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041166297
Total Pages : 274 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Landmark Decisions of the ECJ in Direct Taxation by : Werner Haslehner

Download or read book Landmark Decisions of the ECJ in Direct Taxation written by Werner Haslehner and published by Kluwer Law International B.V.. This book was released on 2015-10-28 with total page 274 pages. Available in PDF, EPUB and Kindle. Book excerpt: Every professional dealing with taxation in the European Union will greatly appreciate this extraordinarily useful book. Based on a high-level conference held at the University of Luxembourg in 2014, the book presents detailed expert summaries and analyses of landmark ECJ decisions in direct taxation, each case a starting point for the development of a specific doctrine. The depth of the analysis, as each author charts a way through the nuances of the Court's arguments, allows the reader to gain an unparalleled understanding of changes in the relevant subsequent jurisprudence. The fundamental issues covered are the following: - taxation of non-residents in the EU context; - implications of EU fundamental freedoms in the income tax systems of the Member States; - outbound and inbound dividend taxation; - taxation of permanent establishments; - restrictions on freedom of establishment; - tax treatment of corporate exit; - abuse of taxpayers' rights; - cohesion of the tax system as an overriding factor in the public interest; - juridical double taxation arising from the exercise of overlapping powers of two or more States; - free movement of capital and third countries; and - tax treatment of non-profit organizations in the cross-border context. The book as a whole offers an incomparable critical assessment of the strengths and weaknesses of the Court's reasoning and its path through the complex field of crossborder income taxation, particularly in the area of the compatibility of national tax legislation with the fundamental freedoms, which continues to be a powerful driver for changes to existing tax laws. For legal academics, this is a unique and fundamental source of essential information and analysis. Crucially, although valuable as a 'snapshot' of the current state of EU tax law, this book will remain relevant for practitioners and policymakers as jurisprudence continues to develop over the years to come.

EC Law and the Sovereignty of the Member States in Direct Taxation

Author : Mathieu Isenbaert
Publisher : IBFD
ISBN 13 : 9087220677
Total Pages : 925 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis EC Law and the Sovereignty of the Member States in Direct Taxation by : Mathieu Isenbaert

Download or read book EC Law and the Sovereignty of the Member States in Direct Taxation written by Mathieu Isenbaert and published by IBFD. This book was released on 2010 with total page 925 pages. Available in PDF, EPUB and Kindle. Book excerpt: In order to develop a suitable framework for the analysis of the European Court of Justice (ECJ) case law, it is first analysed what significance, if any, the concept of 'sovereignty' has in the contemporary supranational environment of the European Union. All too often, tax scholars equate 'sovereignty' with the concepts of 'competence' or 'jurisdiction'. It will be established in this thesis that a much more specific and higher-level meaning is to be attributed to the 'sovereignty' concept, which goes beyond the strictly legal concepts of 'competence' or 'jurisdiction'. The cornerstone of this thesis, however, is an extensive analysis of the case law of the ECJ in direct tax matters, including a comparison with its non-tax case law. A new kind of methodology is used in discussing the cases: they are categorized according to whether a discrimination - or a restriction - based analysis was applied by the ECJ.

Taxation in the European Community

Author : A. J. Easson
Publisher : Burns & Oates
ISBN 13 :
Total Pages : 360 pages
Book Rating : 4.3/5 (512 download)

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Book Synopsis Taxation in the European Community by : A. J. Easson

Download or read book Taxation in the European Community written by A. J. Easson and published by Burns & Oates. This book was released on 1993 with total page 360 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book considers the tax provisions of the Treaty of Rome with its late modifications. Particular attention is given to fiscal discrimination, harmonization of VAT, excise duties and other indirect taxes, taxes and the capital market.

EU Law of the Overseas

Author : Dimitry Kochenov
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041142738
Total Pages : 554 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis EU Law of the Overseas by : Dimitry Kochenov

Download or read book EU Law of the Overseas written by Dimitry Kochenov and published by Kluwer Law International B.V.. This book was released on 2011-05-23 with total page 554 pages. Available in PDF, EPUB and Kindle. Book excerpt: Millions of British, Dutch, French, Danish, Spanish, and Portuguese nationals permanently reside in the overseas parts of their Member States. These people, like the companies registered in such territories, often find it virtually impossible to determine what law applies when legal decisions are required. Although Article 52(1) of the EU Treaty clearly states that EU law applies in the territory of all the Member States, most Member State territories lying outside of Europe provide examples of legal arrangements deviating from this rule. This book, for the first time in English, gathers these deviations into a complex system of rules that the editor calls the ‘EU law of the Overseas’. Member States’ territories lying far away from the European continent either do not fall within the scope of EU law entirely, or are subject to EU law with serious derogations. A huge gap thus exists between the application of EU law in Europe and in the overseas parts of the Member States, which has not been explored in the English language literature until now. This collection of essays sets out to correct this by examining the principles of Union law applicable to such territories, placing them in the general context of the development of European integration. Among the key legal issues discussed are the following: internal market outside of Europe; the protection of minority cultures; EU citizenship in the overseas countries and territories of the EU; Article 349 TFEU as a source of derogations; The implications of Part IV TFEU for the overseas acquis; participatory methods of reappraisal of the relationship between the EU and the overseas; implications for the formation of strategic alliances; voting in European elections; what matters may be referred by courts and tribunals in overseas countries and territories; application of the acquis to the parts of the Member States not controlled by the government or excluded from ratione loci of EU law; interplay of the Treaty provisions and secondary legislation in the overseas; customs union; wholly internal situations; free movement of capital and direct investments in companies; the euro area outside of Europe; duty of loyal cooperation in the domain of EU external action; territorial application of EU criminal law; and territorial application of human rights treaties. Twenty-two leading experts bring their well-informed perspectives to this under-researched but important subject in which, although rules abound and every opportunity to introduce clarity into the picture seems to be present, the situation is far from clear. The book will be welcomed by serious scholars of European Union law and by public international lawyers, as well as by policy-makers and legal practitioners.

European Union Law

Author : Robert Schütze
Publisher : Cambridge University Press
ISBN 13 : 1107071208
Total Pages : 1065 pages
Book Rating : 4.1/5 (7 download)

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Book Synopsis European Union Law by : Robert Schütze

Download or read book European Union Law written by Robert Schütze and published by Cambridge University Press. This book was released on 2015-04-02 with total page 1065 pages. Available in PDF, EPUB and Kindle. Book excerpt: Provides a clear yet rigorous coverage of all the core topics of EU law, with numerous case extracts and one hundred visual aids.

Fiscal Sovereignty of the Member States in an Internal Market

Author : Jacobus Johannes Maria Jansen
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041134034
Total Pages : 274 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Fiscal Sovereignty of the Member States in an Internal Market by : Jacobus Johannes Maria Jansen

Download or read book Fiscal Sovereignty of the Member States in an Internal Market written by Jacobus Johannes Maria Jansen and published by Kluwer Law International B.V.. This book was released on 2011-01-01 with total page 274 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book deals with national sovereignty of Member States in tax matters, and the tensions created by the fact that the decisions by the European Court of Justice requires them to exercise consistently with the Community law. Contributions in the book cover a variety of critical issues, including the current and possible future effects of the internal market on the fiscal sovereignty of Member States; the limits that European law imposes on Member States' policy sovereignty in matters of international tax law; the effect of European law on taxes levied by local authorities; and the consequences the Treaty of Lisbon may have for Member States' fiscal sovereignty.

International Juridical Double Taxation from an Ability-to-Pay Perspective under EU Law

Author : Maria Júlia Ildefonso Mendonça
Publisher : Kluwer Law International B.V.
ISBN 13 : 9403503084
Total Pages : 381 pages
Book Rating : 4.4/5 (35 download)

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Book Synopsis International Juridical Double Taxation from an Ability-to-Pay Perspective under EU Law by : Maria Júlia Ildefonso Mendonça

Download or read book International Juridical Double Taxation from an Ability-to-Pay Perspective under EU Law written by Maria Júlia Ildefonso Mendonça and published by Kluwer Law International B.V.. This book was released on 2023-01-22 with total page 381 pages. Available in PDF, EPUB and Kindle. Book excerpt: The hurdles emerging from the parallel exercise of Member States’ tax sovereignty have been examined by the CJEU and intensely discussed by scholars. By uncovering a paradox in the CJEU’s case law, this groundbreaking book provides a constructive alternative to the deadlock created by the CJEU when ruling that international juridical double taxation, although constituting an obstacle to free movement, is not contrary to EU law. The book – the first in-depth treatment of this perspective – enables taxpayers facing international juridical double taxation to understand how their ability to pay is protected under EU law and the limitations that protection faces. Every aspect of the matter is rigorously examined, including the following: important differences between the traditional notion of double taxation and the current definition under Council Directive 2017/1852; legal means and methods designed to eliminate international juridical double taxation and the policies underlying them; freedoms of movement as prohibitions that limit the exercise of Member States’ taxing powers; consideration of expenses related to economic activity and personal and family circumstances; and in-depth discussion of taxation of income derived from source versus residence Member State. Throughout the book, the author refers to the case law of the CJEU on both international juridical double taxation and taxpayers’ ability to pay, as well as the relevant academic literature, allowing the reader to understand the current state of EU law on these matters and their relation. The author’s remarkable venture into this challenging field, with a deeply informed construction of instrumental categories and critical review of their content, culminates with a viable reformulation of the serious and growing problem of international juridical double taxation. The book will be welcomed by taxation professionals in practice, policymakers, and academia.

The Acte Clair in EC Direct Tax Law

Author : Ana Paula Dourado
Publisher : IBFD
ISBN 13 : 9087220367
Total Pages : 536 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis The Acte Clair in EC Direct Tax Law by : Ana Paula Dourado

Download or read book The Acte Clair in EC Direct Tax Law written by Ana Paula Dourado and published by IBFD. This book was released on 2008 with total page 536 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book discusses the legal issues arising from the search for certainty in the relationship between Community law and direct tax law. In addition, it contains an in-depth analysis of the CILFIT doctrine in action and its demand for legal certainty. By looking at both how the case law of the European Court of Justice (ECJ) in the area of direct taxation fits the CILFIT criteria (ECJ, 6 October 1982, case 283/81, Srl CILFIT and Gavardo SpA), and how such criteria are complied with by national courts, the book reviews and discusses the application in the field of direct taxation of the criteria put forward by the ECJ. The book highlights some of the current challenges faced by the EU judicial system in view of the expansion of EU law and its decentralized application at national level.

Charity Crossing Borders

Author : Sabine Heidenbauer
Publisher : Kluwer Law International B.V.
ISBN 13 : 9041139524
Total Pages : 328 pages
Book Rating : 4.0/5 (411 download)

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Book Synopsis Charity Crossing Borders by : Sabine Heidenbauer

Download or read book Charity Crossing Borders written by Sabine Heidenbauer and published by Kluwer Law International B.V.. This book was released on 2011-09-20 with total page 328 pages. Available in PDF, EPUB and Kindle. Book excerpt: Throughout the European Union, national income tax systems support charitable activities by way of preferential treatment. However, a number of Member States operate relief regimes which appear to trigger the question of compatibility with Union law with respect to the fundamental freedoms. In this first study to examine charity and donor taxation regimes across a wide range of Member States, the author focuses on compatibility with EU non-discrimination law. She examines twenty national regimes, both comparatively and from the perspective of overarching EU law. The countries covered are Austria, Belgium, Bulgaria, Cyprus, Estonia, Finland, Germany, Hungary, Ireland, Italy, Latvia, Lithuania, Malta, The Netherlands, Poland, Portugal, Slovakia, Spain, Sweden, and the United Kingdom. Although charity and donor taxation falls within the competence of the Member States, they must nonetheless observe primary Union law and grant non-discriminatory treatment where a fact pattern falls within the ambit of the fundamental freedoms. In the course of defining this framework, the study addresses such issues as the following: types of relief schemes maintained for charities and donors; administrative requirements; international aspects (both inbound and outbound); privileged donations and capital gains treatment of in-kind donations; eligible donees; whether and to what extent charitable entities and donors can actually rely on the fundamental freedoms; specific applicability of each of the relevant fundamental freedoms; the issue of comparability; justifications for restrictive measures in Member State practice; and the issue of proportionality.

Harmful Tax Competition An Emerging Global Issue

Author : OECD
Publisher : OECD Publishing
ISBN 13 : 9264162941
Total Pages : 82 pages
Book Rating : 4.2/5 (641 download)

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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.

The Netherlands in International Tax Planning

Author : Johann Müller (podatki)
Publisher : IBFD
ISBN 13 : 9087220243
Total Pages : 417 pages
Book Rating : 4.0/5 (872 download)

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Book Synopsis The Netherlands in International Tax Planning by : Johann Müller (podatki)

Download or read book The Netherlands in International Tax Planning written by Johann Müller (podatki) and published by IBFD. This book was released on 2007 with total page 417 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book provides international tax professionals with a practical guide on dealing with the Dutch taxation of business investments into the Netherlands, via the Netherlands (conduit structures), or from the Netherlands. The book focuses on corporate income tax, dividend tax and capital duty, as well as other issues typical of an international environment (participation exemption, the current state of the ruling practice, financing). The contents include: introduction to Dutch domestic law, including both corporate and personal income tax, dividend withholding tax, VAT, real estate transfer tax; an in-depth analysis of the Dutch corporate income tax system including financing a taxpayer, tax consolidation, holding companies and participation exemption, corporate reorganizations, financing companies, transfer pricing, loss compensation, inbound investments and anti-abuse legislation; participation exemption and Dutch interest limitation rules; royalty and interest income box, an overview of Dutch international law examining treaties, the tax agreement for the Kingdom of the Netherlands, the unilateral decree for the prevention of double taxation and EU law; a description of Dutch dividend tax including EU entities and dividend tax credit; an overview of the exchange of information including national law, the ruling practice, treaties and EU law; a description of the personal income tax, including 30% cost allowance and employee stock option plans.

Corporate Income Taxation in Europe

Author : Michael Lang
Publisher : Edward Elgar Publishing
ISBN 13 : 1782545425
Total Pages : 384 pages
Book Rating : 4.7/5 (825 download)

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Book Synopsis Corporate Income Taxation in Europe by : Michael Lang

Download or read book Corporate Income Taxation in Europe written by Michael Lang and published by Edward Elgar Publishing. This book was released on 2013-10-31 with total page 384 pages. Available in PDF, EPUB and Kindle. Book excerpt: The book considers the impact of the CCCTB from the perspective of non-EU-based enterprises that are carrying on business in the EU through the operation of branches or subsidiaries in member states. It incorporates the perspectives of leading scholars

Tax Co-ordination in the European Union

Author : Ben Patterson
Publisher : Virago Press
ISBN 13 :
Total Pages : 120 pages
Book Rating : 4.F/5 ( download)

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Book Synopsis Tax Co-ordination in the European Union by : Ben Patterson

Download or read book Tax Co-ordination in the European Union written by Ben Patterson and published by Virago Press. This book was released on 2001 with total page 120 pages. Available in PDF, EPUB and Kindle. Book excerpt: This is an updated study of a 1998 publication, "Tax competition in the European Union". The introduction covers the recent history of tax policy within the EU, and examines the current situation in corporate taxation, taxation of savings, taxation of labour, and indirect taxation (VAT and excise duty). A comparative analysis provides a detailed survey of how direct taxes - corporate and personal - are levied within the EU. The final section discusses the main issues in the current debate on the alternative approaches of competition and co-operation in the taxation field.