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Author: Michael Lang
Publisher: Edward Elgar Publishing
ISBN: 1782545425
Category : Law
Languages : en
Pages : 384
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Book Description
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
Author: Michael Lang
Publisher: Edward Elgar Publishing
ISBN: 1782545425
Category : Law
Languages : en
Pages : 384
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Book Description
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
Author: Michael Lang
Publisher:
ISBN: 9783707313062
Category : Corporations
Languages : en
Pages : 1101
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Book Description
Author: Christian Valenduc
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
Author: Dennis Weber
Publisher: Kluwer Law International B.V.
ISBN: 9041192689
Category : Law
Languages : en
Pages : 272
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Book Description
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.
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:
Publisher:
ISBN: 9789013097450
Category :
Languages : nl
Pages : 266
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Book Description
Author: Dennis Weber
Publisher: Kluwer Law International B.V.
ISBN: 9041140697
Category : Law
Languages : en
Pages : 368
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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: Carsten Wendt
Publisher: Springer Science & Business Media
ISBN: 3834981931
Category : Business & Economics
Languages : en
Pages : 247
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Book Description
Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.
Author: I.M. de Groot
Publisher:
ISBN:
Category :
Languages : en
Pages :
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Book Description
On 25 October 2016, the European Commission published a corporate tax reform package including a Proposal for a Council Directive on a Common Corporate Tax Base (CCTB), COM(2016) 685 final, and a Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB), COM(2016) 683 final. This article deals with the participation exemption, the switchover clause and the CFC rules. The author compares the proposals with the 2011 CCCTB proposal and the Anti Tax Avoidance Directive (ATAD).
Author: Matthias Petutschnig
Publisher:
ISBN:
Category :
Languages : en
Pages : 0
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Book Description
One of the main features of the common consolidated corporate tax base (CCCTB) Draft Directive, the formulary apportionment of the consolidated group income, leads to a significant change in corporate income taxation paradigms. Currently, corporations are taxed on a separate entity basis using the arm's length principle to evaluate intra-group transactions. Similarly company law uses a separate entity approach with regard to transactions between related parties. The CCCTB Draft Directive will regularly lead to allocation results that are explicitly not at arm's length as the arm's length principle will not be necessary anymore for tax purposes. However, without a corresponding change in company law paradigms - which is not foreseeable - the current lockstep between corporate income tax law and company law will cease to exist. Yet, not only the proposed CCCTB regime but also existing group taxation systems produce taxable outcomes that are not in accordance with the domestic company laws' single entity approaches. This article therefore analyses group taxation systems currently employed by EU Member States and shows that the vast majority of group taxation systems employ instruments to (re-)unite the results from the joint taxation with company law's separate entity approach. These accompanying mechanisms ensure a fair distribution of the advantages and disadvantages of the respective intra-group loss-offset system to all group members. However, due to various reasons, one being the fact that every group member of the CCCTB will be responsible for a share of the group's overall tax liability, another being the fact that different tax rates will apply within one CCCTB group, these currently employed mechanisms and techniques are not suitable for the CCCTB concept. Therefore this article develops a distinct mechanism to share the benefits of the CCCTB concept within the whole group. The current international debate on the suitability of the arm's length to continue as a standard for the allocation of taxing powers in intra-group transactions and the new impetus for the common tax base in some EU Member States may suggest that there is a new potential momentum to make progress in the introduction of formulary apportionment within the European Union.Full-text Paper.
