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 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 Corporate Income Tax in the EU the Common Consolidated Corporate Tax Base CCCTB and Beyond written by Christian Valenduc and published by . This book was released on 2018 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 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 Common consolidated corporate tax base CCCTB written by and published by . This book was released on 2011 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 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 Sharing the Benefits of the EU s Common Consolidated Corporate Tax Base Within Corporate Groups written by Matthias Petutschnig and published by . This book was released on 2023 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.
Download or read book Common Corporate Tax Base CC C TB and Determination of Taxable Income written by Christoph Spengel and published by Springer Science & Business Media. This book was released on 2012-03-13 with total page 130 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 The Common Consolidated Corporate Tax Base and the UK Tax System written by Christiana HJI. Panayi and published by . This book was released on 2011 with total page 96 pages. Available in PDF, EPUB and Kindle. Book excerpt:
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 CCCTB written by J.A.R. van Eijsden and published by . This book was released on 2011 with total page 266 pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book The International Aspects of the European Common Consolidated Corporate Tax Base CCCTB and Their Interaction with Third Countries written by Eid Ashry Gaber Ali and published by . This book was released on 2013 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt:
Download or read book Group Provisions in the 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: The author addresses the participation exemption, the switch-over provision and the controlled foreign company (CFC) rules in the proposals for directives on a Common Corporate Tax Base (CCTB) and a Common Consolidated Corporate Tax Base (CCCTB) published on 25 October 2016. In particular, it focuses on the ambiguities and differences in relation to the draft CCCTB Directive from 2011 and the Anti-Tax Avoidance Directive (ATAD).
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 Corporate Taxation and the European Company Statute written by Emrah Arbak and published by CEPS. This book was released on 2008 with total page 32 pages. Available in PDF, EPUB and Kindle. Book excerpt: