European Union Corporate Tax Law
European Union Corporate Tax Law

Author: Christiana HJI Panayi

Publisher: Cambridge University Press

Published: 2013-05-09

Total Pages: 413

ISBN-13: 1107354986

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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.

Achieving a Common Consolidated Corporate Tax Base in the EU
Achieving a Common Consolidated Corporate Tax Base in the EU

Author: Malcolm Gammie

Publisher: CEPS

Published: 2005

Total Pages: 137

ISBN-13: 9290795999

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"This report offers a positive assessment of the basic compatibility of IFRS and tax principles. It also provides constructive information and guidance to the European Commission to identify the elements of member states' tax systems that must be considered to achieve convergence to a CCCTB from the starting point of IFRS. The Task Force also emphasises, however, that a common corporate tax base among member states is not enough. Any CCCTB should be compatible with the EU's Lisbon objectives. And to meet those objectives, there needs to be a single common tax base with consolidation and allocation, in a form that is competitive, efficient and flexible."--BOOK JACKET.

Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income
Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income

Author: Christoph Spengel

Publisher: Springer Science & Business Media

Published: 2012-03-13

Total Pages: 130

ISBN-13: 3642284337

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The study conducted by the Centre of European Economic Research (ZEW), the University of Mannheim and Ernst & Young contributes to the ongoing evaluation of the proposal for a Draft Council Directive on a Common Consolidated Corporate Tax Base (CC(C)TB) released by the European Commission on March 16, 2011. For the first time, details on the determination of taxable income under the proposed Council Directive are compared to prevailing corporate tax accounting regulations in all 27 Member States, Switzerland and the US. The study presents evidence on the scope of differences and similarities between national tax accounting regulations and the Directive’s treatment in a complete, yet concise form. Based on this comprehensive comparison, it goes on to discuss remaining open questions and adjustments needed if the Directive is to be implemented in national tax law. Readers seeking a basis for taking an active part in the public debate will find a valuable source of information and a first impression of how the proposed CC(C)TB would affect corporate tax burdens in the European Union.

Corporate Income Tax Harmonization in the European Union
Corporate Income Tax Harmonization in the European Union

Author: D. Pîrvu

Publisher: Springer

Published: 2012-08-13

Total Pages: 386

ISBN-13: 1137000910

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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.

Combating Tax Avoidance in the EU
Combating Tax Avoidance in the EU

Author: José Manuel Almudí Cid

Publisher: Kluwer Law International B.V.

Published: 2018-12-20

Total Pages: 880

ISBN-13: 9403501421

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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.

CCCTB
CCCTB

Author: Dennis Weber

Publisher: Kluwer Law International B.V.

Published: 2012-05-10

Total Pages: 441

ISBN-13: 9041140697

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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.

Double Taxation Within the European Union
Double Taxation Within the European Union

Author: Alexander Rust

Publisher:

Published: 2011

Total Pages: 0

ISBN-13: 9789041135254

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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.

Harmful Tax Competition An Emerging Global Issue
Harmful Tax Competition An Emerging Global Issue

Author: OECD

Publisher: OECD Publishing

Published: 1998-05-19

Total Pages: 82

ISBN-13: 9264162941

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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.

A Common Consolidated Corporate Tax Base for Europe – Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa
A Common Consolidated Corporate Tax Base for Europe – Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa

Author: Wolfgang Schön

Publisher: Springer Science & Business Media

Published: 2008-04-24

Total Pages: 196

ISBN-13: 3540794840

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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.

Transfer Pricing in SMEs
Transfer Pricing in SMEs

Author: Veronika Solilova

Publisher: Springer

Published: 2017-10-31

Total Pages: 205

ISBN-13: 3319690655

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This book provides a detailed assessment of current approaches to transfer pricing in the context of small- and middle-sized enterprises (SMEs), including the newest update of Transfer Pricing Guidelines from 10 July 2017. It analyzes the transfer pricing rules for SMEs across the European Union (EU) and explores two alternative approaches as suitable solutions for current transfer pricing issues. The authors evaluate and discuss alternative approaches like Safe Harbour and Common Consolidated Corporate Tax Base (CCCTB). Taking into account the prominent role of SMEs in the European Union’s economy, the book also puts forward policy recommendations to achieve the long-term goals of the EU’s 2020 agenda.