Download or read book A Review of the EU s Proposals for a Common consolidated Corporate Tax Base written by S. Bhogal and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: This article discusses the challenges facing the European Commission's renewed effort to introduce a common consolidated corporate tax base in the EU.
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 272 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.
Download or read book The European Commission s Proposal for a Common Consolidated Corporate Tax Base written by Clemens Fuest and published by . This book was released on 2010 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Commission is currently preparing a proposal for a directive on the introduction of a common consolidated corporate tax base (CCCTB). This paper reviews the current state of the European Commission's preparation of the CCCTB proposal and discusses the implications for efficiency and fairness of the tax system. The analysis concludes that more evidence of significant economic benefits from introducing a CCCTB would be required to generate widespread support for the project.
Download or read book Common Consolidated Corporate Tax Base written by Michael Lang and published by . This book was released on 2008 with total page 1101 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 368 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.
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
Download or read book Towards a Neutral Formulary Apportionment System in Regional Integration written by Shu-Chien Chen and published by Kluwer Law International B.V.. This book was released on 2023-03-09 with total page 471 pages. Available in PDF, EPUB and Kindle. Book excerpt: International tax regimes and practices are heavily criticized for failing to fairly levy corporate tax on giant multinational taxpayers in the current globalized and digitalized world. This important and far-seeing book demonstrates how formulary apportionment (FA) – an approach by which a multinational corporation pays each jurisdiction’s corporate tax based on the share of its worldwide income allocated to that jurisdiction – can achieve the much-sought goal of aligning value creation and taxation. The author, through an intensive analysis of the European Union’s (EU’s) Common Consolidated Corporate Tax Base (CCCTB) Directive Proposal(s) and comparison to the United States (US’s) formulary apportionment experience, shows how the perceived problems with an FA system can be overcome and lays out the necessary elements for its feasibility. With detailed attention to the debates around formulary apportionment and its theoretical foundations, the book provides a blueprint for rebuilding the normative framework for the EU’s tax reform by clearly analysing the implications of the following and more: theorising public benefits to be represented by taxation; reorganising different economic theories about tax neutrality and tax justice; advancing the comparative legal research methodology to analyse law reform by combining the functional approach and the problem-solving approach; designing the logical formulary apportionment system for digital economy; ensuring the removal of the incentive for multinationals to shift reported income to low-tax locations; reducing the tax system’s complexity and the administrative burden it imposes on firms; eliminating transfer pricing complexity for intra-firm transactions; achieving equal weighting of the sales factor, the labour factor, and the asset factor in the formula; application of ‘destination-based’ rule for attributing the sales factor; and replacing the traditional permanent establishment nexus with a ‘factor presence nexus’. The presentation incorporates extensive comparison between the EU’s formulary apportionment tax reform option and FA systems existing in the United States (US) at state level, including reference to relevant US case law and legislation. As a possible option to address the problem of base erosion and profit shifting (BEPS), formulary apportionment is gaining increasing acceptance and attention. This book will prove invaluable to taxation authorities, tax practitioners, and scholars in its deeply informed and systematic guidance on good practices and prevention of problematic experiences in establishing and implementing an effective and market-neutral FA system.
Download or read book Common Corporate Tax Base CC C TB and Determination of Taxable Income written by Christoph Spengel and published by Springer. This book was released on 2012-03-16 with total page 104 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book EU CCCTB the Potential Successes and Challenges written by S. Bhogal and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Commission re-launched its proposal to introduce a common consolidated corporate tax base (CCCTB) on 25 October 2016, with the aim of creating a level playing field for multinationals in Europe and creating a simple and pro-business tax environment. The authors of this article give their opinion on the plan and whether this attempt may succeed.
Download or read book The European Commission Proposal for a Common Consolidated Corporate Tax Base written by Clemens Fuest and published by . This book was released on 2008 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Re Launch of the Proposal for a Common Consolidated Corporate Tax Base CCCTB in the EU written by Shafi UK Niazi and published by . This book was released on 2017 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: The European Commission has recently announced to revisit its earlier draft legislation on CCCTB. The article analyses the CCCTB re-launch and investigates changes in the new policy move. Except that the new CCCTB regime is mandatory for companies, no other significant departure is apparently visible in the ultimate long-term objectives of the revised plan. However, the article argues that there is a remarkable shift in the pursuit of a path towards a CCCTB system. It evaluates the changed course of action against the European constraints and integrational theories as well as the growing global imperatives of contemporary tax policymaking pursuant in particular to the BEPS project. The study concludes that the new direction set forth by the Commission is pragmatic and it is likely that the shift may, for the first time in European history, result in tangible progress on rules for a common tax base in the single market.
Download or read book Effective Corporate Tax Rate And Digital Business Establishment in the Corporate Tax Base Proposals written by and published by . This book was released on 2017 with total page 4 pages. Available in PDF, EPUB and Kindle. Book excerpt: On 25 October 2016, the Commission presented two proposals for two Council directives on a Common Corporate Tax Base, COM (2016)0685 (CCTB) and a Common Consolidated Corporate Tax Base, COM (2016)0683 (CCCTB). They both are based of Article 115 TFEU (Council decides after consultation of EP- special legislative procedure). As approximation under this Article shall directly affect the establishment or functioning of the internal market the Council decides by unanimity (exception for fiscal provisions in Article 114, par. 2 TFEU). The purpose of the proposals is to establish common rules for corporate taxes and to make it possible for corporations to submit a single consolidated tax declaration for the corporation's activities to the tax authority in only one EU Member State. The proposals shall ensure a corporate tax system that encourages fairness in the internal market as currently businesses with cross-border activity have to comply with up to 28 divergent corporate tax systems (generally, corporate income is taxed at national level).
Download or read book Concernbepalingen in de Common Consolidated Corporate Tax Base written by I.M. de Groot and published by . This book was released on 2017 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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).
Download or read book Taxation of European Companies at the Time of Establishment and Restructuring written by Christiane Malke and published by Springer Science & Business Media. This book was released on 2010-05-07 with total page 282 pages. Available in PDF, EPUB and Kindle. Book excerpt: Christiane Malke analyzes the current issues resulting from the entry into a Societas Europaea (SE), the transfer of seat of an SE from one EU member state to another and the exit out of an SE in the 27 member states of the EU taking into consideration the Merger Directive. Based on existing deficiencies the author provides reform approaches that consider changes to the national law of the member states, to EU law as well as to the proposals provided by the European Commission regarding the introduction of a Common (Consolidated) Corporate Tax Base.
Download or read book Local and Regional Corporate Taxes Across the EU written by and published by . This book was released on 2011 with total page 25 pages. Available in PDF, EPUB and Kindle. Book excerpt: "The European Commission's Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) was released on 16 March 2011 along with an impact assessment. The proposed legislation is seen by the Commission as a means of tackling some major fiscal impediments to growth in the Single Market, in line with the priorities set in Europe 2020. However, little consideration appears to have been given to the implications of the legislation for local and regional authorities (LRAs) either in the Commission's proposal or in the accompanying impact assessment. The purpose of this briefing is to contribute to addressing this oversight, by setting out some of the implications of the proposed legislation for LRAs."--Editor.
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.
Download or read book Modelling Corporate Tax Reform in the EU written by Joint Research Center of the European Commission IPTS. and published by . This book was released on 2016 with total page 136 pages. Available in PDF, EPUB and Kindle. Book excerpt: This report investigates the economic impact of the European Commission proposal for a common corporate tax base (CCTB) and a common consolidated corporate tax base with formula apportionment (CCCTB) within the EU. Furthermore, on top of the common base, it considers proposals to reduce the debt bias in corporate taxation. To do so, a general equilibrium model (CORTAX) is applied. The model covers all EU Member States, features different firm types and models many key features of corporate tax regimes, including multinational profit shifting, investment decisions, loss compensation and the debt-equity choice of firms. In this research the economic impact of C(C)CTB is assessed and the results of this economic modelling evaluation suggest that a fairer and more efficient tax system can be introduced whilst maintaining, and perhaps improving, GDP and welfare in the EU.
