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Author: Christiana HJI Panayi
Publisher: Cambridge University Press
ISBN: 1107354986
Category : Law
Languages : en
Pages : 413
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Book Description
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.
Author: Christiana HJI Panayi
Publisher: Cambridge University Press
ISBN: 1107354986
Category : Law
Languages : en
Pages : 413
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Book Description
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.
Author: Christoph Spengel
Publisher: Springer Science & Business Media
ISBN: 3642284337
Category : Law
Languages : en
Pages : 130
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Book Description
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.
Author: Dieter Endres
Publisher:
ISBN: 9789041145567
Category : Corporations
Languages : en
Pages : 0
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Book Description
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.
Author: Dennis Weber
Publisher: Kluwer Law International B.V.
ISBN: 9041140697
Category : Law
Languages : en
Pages : 441
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Book Description
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.
Author: OECD
Publisher: OECD Publishing
ISBN: 9264162941
Category :
Languages : en
Pages : 82
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Book Description
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.
Author: Sebastian Beer
Publisher: International Monetary Fund
ISBN: 1513528327
Category : Business & Economics
Languages : en
Pages : 51
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Book Description
Schemes of residual profit allocation (RPA) tax multinationals by allocating their ‘routine’ profits to countries in which their activities take place and sharing their remaining ‘residual’ profit across countries on some formulaic basis. They have recently and rapidly come to prominence in policy discussions, yet almost nothing is known about their impact on revenue, investment and efficiency. This paper explores these issues, conceptually and empirically. It finds residual profits to be substantial, but concentrated in a relatively few MNEs, headquartered in few countries. The impact on tax revenue of reallocating excess profits under RPA, while adverse for investment hubs, appears beneficial for lower income countries even when the formula allocates by destination-based sales. The impact on investment incentives is ambiguous and specific both to countries and MNE groups; only if the rate of tax on routine profits is low does aggregate efficiency seem likely to increase.
Author: Peter Harris
Publisher: Cambridge University Press
ISBN: 1107033535
Category : Business & Economics
Languages : en
Pages : 651
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Book Description
A comprehensive and comparative analysis of corporate tax systems, focusing on structural defects and how they are addressed in practice.
Author: Dieter Endres
Publisher: Kluwer Law International B.V.
ISBN: 9041125507
Category : Law
Languages : en
Pages : 850
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Book Description
This book discusses whether elements of the international financial reporting standards (IFRS) meet the requirements of potential common European tax accounting rules. The analysis is based on general principles of taxation and on a comprehensive comparative survey of selected IFRS and tax accounting rules for all 25 EU member states (conducted by the universities of Goettingen, Mannheim, and Erlangen-Nuremberg with the support of PricewaterhouseCoopers). It concludes that, in principle, there is no irresolvable conflict between IFRS and the current tax accounting rules in the member states. After an introduction the book considers the general principles of taxation, followed by a comparative survey of IFRS and tax accounting rules in the EU member states, including taxation of corporations, determination of income, recognition, initial measurement, subsequent measurement, and special areas: pensions, leasing, treatment of domestic and foreign losses, and group taxation. Then follows an analysis of common and fundamental accounting principles, including conceptual accounting principles, accrual principles, treatment of losses, and definition of a group and consolidation. The appendices show how each country computes taxable income and grants tax incentives.
Author: Christiana HJI Panayi
Publisher: Edward Elgar Publishing
ISBN: 1788110846
Category : Law
Languages : en
Pages : 663
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Book Description
Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both direct and indirect taxation. The important issues and debates arising from these general principles are expertly unpicked, with leading scholars examining the status quo as well as setting out a clear agenda for future research.
Author: Mario Grandinetti
Publisher: Kluwer Law International B.V.
ISBN: 9041167463
Category : Law
Languages : en
Pages : 437
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Book Description
The recent relaunch of the European Commission’s Common Consolidated Corporate Tax Base (CCCTB) project promises a sorely needed leap forward in the harmonization of the rules by which companies calculate their taxable profits. In particular, the initiative hopes to remedy the severe barrier to cross-border business caused by the ‘the accounting Tower of Babel’ by which companies’ tax bases are determined under national law. This thorough analysis and commentary covers the influence of accounting rules on tax, considering both generally accepted standards – international accounting standards (IAS) and international financial reporting standards (IFRS) – and EU Directive 2013/34. Three introductory chapters usher in detailed comparative overviews of the effect of these rules on taxation in nine EU Member States as well as in two other major EU trading partners, the United States and Brazil. Fully explaining the remarkable recent improvement in the comparability of accounts that represent favourable preconditions for creating a single market for financial services within the EU, this book covers every relevant detail, including the following and much more: – criterion of evaluation of alternative fixed assets based on revaluated amounts; – criterion based on fair value; – provisions applicable to income statements, notes, reports, and financial statements; – rules applicable to the publication of documents; – transparency in payments to governments; – dispositions on exemptions; – hierarchy of general provisions and principles; – balance sheet and profit and loss account; – simplifications for small and medium-sized enterprises (SMEs); – system of creditors’ protection; and – protection of investors’ interests. This book is a peerless explication of the taxation choices granted to Member States under IAS/IFRS and EU Directive 2013/34 and how they will be affected by ongoing Commission initiatives. Because relevant, timely, reliable, and comparable information assumes a leading role in protecting the interests of investors, creditors, and other stakeholders, as well as in ensuring that all operators act on a level playing field under equal conditions, the analysis presented here is of immeasurable value to lawyers, business persons, and officials concerned with taxation, not only in Europe but anywhere within the reach of international trade.
