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 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 International Company Taxation and Tax Planning written by Dieter Endres and published by . This book was released on 2015 with total page 0 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Corporate Income Tax Harmonization in the European Union written by D. Pîrvu and published by Springer. This book was released on 2012-08-13 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Corporate Tax Law written by Peter Harris and published by Cambridge University Press. This book was released on 2013-03-07 with total page 651 pages. Available in PDF, EPUB and Kindle. Book excerpt: Many corporate tax systems lack structure. Focusing on structural defects and how they are addressed in practice, this comprehensive and comparative analysis of corporate tax systems uses a conceptual framework to illustrate and analyse the many difficult issues corporations pose. This framework is enhanced by the examination of a large body of legal rules and practical considerations which demonstrate how corporate tax systems work in practice. While adopting a broad comparative approach, the analysis also drills down into the detail of influential corporate tax systems in order to illustrate the major issues they face and the options available to them.

Download or read book A missing link in the analysis of global value chains cross border flows of intangible assets taxation and related measurement implications written by World Intellectual Property Organization and published by WIPO. This book was released on 2017 with total page 60 pages. Available in PDF, EPUB and Kindle. Book excerpt: Understanding cross-border flows of disembodied knowledge, often associated with intellectual property (IP), is essential to analyzing how modern economies operate. This paper documents how available data to document these IP flows are distorted by various factors, including tax planning by multinational enterprises. It finds that tax-induced mismeasurement could be more than 35%, and greater for individual countries particularly high-tax-rate countries.

Download or read book The Impact of Tax Treaties and EU Law on Group Taxation Regimes written by Bruno da Silva and published by Kluwer Law International B.V.. This book was released on 2016-07-11 with total page 789 pages. Available in PDF, EPUB and Kindle. Book excerpt: Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.

Download or read book The Determination of Corporate Taxable Income in the EU Member States written by Dieter Endres and published by Kluwer Law International B.V.. This book was released on 2007-01-01 with total page 850 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Taxes and Taxation Trends written by Jolanta Iwin-Garzyńska and published by BoD – Books on Demand. This book was released on 2018-04-20 with total page 274 pages. Available in PDF, EPUB and Kindle. Book excerpt: Taxes are a constant part of life for every company and a constant element of economics, finance, and financial law. Any changes observed in the science and theory also apply to the importance and position of taxes in the practice of corporate finance, public finance, and economic growth. Beside this, a new meaning of taxes in the economies of countries in the world and the European Union is introduced. Taxes will always introduce risks and uncertainties in business, due to the high volatility and uncertainty of tax law. Moreover, being a category that affects the economic growth, they cause disturbances in stability and welfare of the state. Therefore, while considering the essence of taxes in a country, one should not consider this category in isolation from corporate finance and social welfare. Two things are certain in the world: death and taxes.

Download or read book Transfer Pricing in SMEs written by Veronika Solilova and published by Springer. This book was released on 2017-10-31 with total page 205 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book The European Union beyond the Crisis written by Boyka M Stefanova and published by Lexington Books. This book was released on 2014-11-14 with total page 357 pages. Available in PDF, EPUB and Kindle. Book excerpt: This volume explores institutional and policy developments in the EU and its member states in a parallel examination of citizens’ views of the effectiveness of crisis response reflected in public trust, output legitimacy, and satisfaction with democracy. Our approach to understanding the crisis posits EU-level governance and institutional change, national-level policymaking, and domestic politics as interrelated, interdependent domains of political action and public spheres that collectively shape the political landscape of post-crisis Europe. The volume sheds new light on the relationship among the institutional, policy, and polity consequences of the crisis. The book has two fundamental aims. The first is to demonstrate the interconnected nature of European governance, domestic reform, and democratic politics. The unprecedented complexity of the financial, sovereign debt, economic, and social crises in Europe has led to a political crisis that reflects the struggle to effectively address its various causes and effects. The second objective is to present a theoretically informed assessment of the consequences of the European crises for state-society relations and democratic legitimacy. Our analysis of the crisis in a variety of national contexts and European governance highlights the difficulties faced by political decision-makers. We find that the domestic policy process is selectively affected or disconnected from the process of rule-making at the EU level, that public opinion still matters in the process of policy formation and EU crisis response, and that the salience of the EU agenda in the domestic public sphere increasingly depends on the preferences of political actors. Public response to the crisis has become increasingly complex as well, ranging from declining trust in the political institutions, emerging national stereotypes, changing expectations of the EU level of crisis response, growing disconnect between political parties and voters, and evolving intra-regional distinctions across the EU’s east-west divide.

Download or read book Offshore Finance and Global Governance written by William Vlcek and published by Springer. This book was released on 2016-11-02 with total page 190 pages. Available in PDF, EPUB and Kindle. Book excerpt: This book analyzes shifting international taxation strategies in pursuit of tax nomads, individuals and companies who minimize their tax obligations among multiple countries. Focusing on the efforts of the United States, the collective endeavours of the European Union and the global initiative of the OECD under G20 guidance, it investigates their attempts to understand and control the mechanisms employed by such nomads. The author directs particular attention to intellectual property, used by multinational corporations to move income from high-tax to low-tax locations. Contrary to claims that globalization hinders tax collection, Vlcek argues that state sovereignty and state power remain the defining characteristic of international taxation. The EU and OECD in turn, he concludes, are leveraging cooperation with the US to force other countries to share taxpayer information with them. This significant work will interest economists, political scientists and tax experts. /div

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 210 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 From Marks and Spencer to X Holding written by Dennis Weber and published by Kluwer Law International B.V.. This book was released on 2011-08-03 with total page 250 pages. Available in PDF, EPUB and Kindle. Book excerpt: Group taxation – special schemes according to which a group of companies meeting certain requirements may be assimilated for tax purposes to a single company – exists in several European Member States and is now under consideration in an EU proposal concerning a common consolidated corporate tax base (CCCTB). Its rationale as a potential EU tax regime has arisen from a series of high-profile ECJ cases concerning cross-border tax relief claims – decisions which have been criticized for lack of clarity and for breach of freedom of establishment (Article 49 TFEU). Group taxation has now become one of the most intensively debated issues in EU tax law. The papers collected in this timely book derive from an ACTL Seminar held at Amsterdam in April 2010. The thirteen authors are either well-known practitioners from major law firms and accounting firms, or noted European tax scholars, or both. Among the central issues covered in the book are the following: the underlying tax obstacles which exist for companies operating in more than one Member State; potential for tax avoidance; prevention of double use of losses (the ‘no possibilities’ test); disadvantages that arise as a consequence of the parallel exercise of fiscal sovereignty; the concept of ‘balanced allocation of taxing powers’; meaning of ‘final losses’; the ‘Bosal fix’; cash-flow disadvantages of having to carry losses forward; deduction of currency losses; deduction-and-recapture rules; and VAT grouping.

Download or read book GAARs and Judicial Anti Avoidance in Germany the UK and the EU written by Markus Seiler and published by Linde Verlag GmbH. This book was released on 2016-06-28 with total page 371 pages. Available in PDF, EPUB and Kindle. Book excerpt: GAARS: the better insight into a country’s tax system In a post-BEPS tax world and in times of an ever-increasing need for tax revenue, policy-makers are more willing than ever to tighten or adopt General Anti-Avoidance Rules (GAARs). A GAAR is typically a broad principle-based rule trying to establish the borderline between “abuse” and “use” of a law, thereby addressing the phenomenon that as long as there have been taxes, persons have been trying to reduce their tax bills. This award-winning book compares the GAARs and judicial anti-avoidance approaches of Germany, the UK and the EU. It gives a deep insight into the predominant legal traditions of the Western World, comprehensively analyses case-law and offers unique perspectives on tax law across jurisdictions. This book reveals that there is no other feature of tax law that provides a better insight into a country’s tax system than its anti-avoidance rules. GAARs and their historical background reveal so much about judicial perspectives on taxation and legal interpretation, citizens’ tax morale, drafters’ inclinations for technical or principled drafting or legislators’ willingness to confront politically sensitive issues. Understanding the role of GAARs ultimately also reveals whether they are a suitable means to counteract tax avoidance effectively. The Book is the winner of the Wolfgang Gassner-Wissenschaftspreis 2016!

Download or read book A Common Consolidated Corporate Tax Base for Europe Eine einheitliche K rperschaftsteuerbemessungsgrundlage f r Europa written by Wolfgang Schön and published by Springer Science & Business Media. This book was released on 2008-04-24 with total page 196 pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.

Download or read book Terra Wattel European Tax Law written by Peter J. Wattel and published by Kluwer Law International B.V.. This book was released on 2018-11-20 with total page 863 pages. Available in PDF, EPUB and Kindle. Book excerpt: Peter J. Wattel is Advocate General in the Supreme Court of the Netherlands, State Councillor extraordinary in the Netherlands Council of State and professor of EU tax law at the Amsterdam Centre for Tax Law (ACTL), University of Amsterdam. Otto Marres is professor at the ACTL and tax lawyer at Meijburg & Co., Amsterdam. Hein Vermeulen is professor at the ACTL and Director of PwC’s EU Direct Tax Group. The seventh edition of this two-volume set brings a comprehensive and systematic survey of European Tax Law up to January 2018. It provides a state of the art clarification and analysis of the implications of the EU Treaties and secondary EU law for national and bilateral tax law. From the consequences of the EU free movement rights - to the soft law meant to put a halt to harmful tax competition. The seventh edition of European Tax Law offers a cutting-edge analysis of the field surrounding tax law across Europe. It puts forward a thought-provoking discussion of the current EU tax rules, as well as of the EU Court’s case law in tax matters. Previous editions were highly regarded as a staple overview of EU tax law among EU tax law practitioners, policymakers, the judiciary and academics alike. With its updated legislation and case-law up to January 2018, this new edition maintains its unparalleled depth and clarity as the go-to reference book in the field. This first volume of ‘European Tax Law’ extensively covers: 1. The consequences of the EU free movement rights, the EU State aid prohibition, the EU Charter of Fundamental Rights and the general principles of EU law for national tax law, tax treaties, national (tax) procedure, State liability and relations with third States, as they appear from the case law of the Court of justice of the EU 2. Secondary EU law in force and proposed on direct taxes: the Parent-Subsidiary Directive, the Tax Merger Directive, the Interest and Royalties Directive, cross-border tax dispute settlement instruments, the Anti-Tax Avoidance Directive and the C(C)CTB proposal 3. The exchange of information and other administrative assistance in the assessment and recovery of taxes between the EU Member States 4. Soft Law on Harmful Tax Competition 5. Procedural matters and the extent of judicial protection The upcoming second volume of this set will cover harmonization of indirect taxation, energy taxation and capital duty, as well as administrative cooperation in the field of indirect taxation.