Group Taxation
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The Taxation Of Corporate Groups Under Consolidation
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Author : Antony Ting
language : en
Publisher: Cambridge University Press
Release Date : 2013
The Taxation Of Corporate Groups Under Consolidation written by Antony Ting and has been published by Cambridge University Press this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with Business & Economics categories.
Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.
Integration Approaches To Group Taxation In The European Internal Market
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Author : Ioanna Mitroyanni
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2008-10-13
Integration Approaches To Group Taxation In The European Internal Market written by Ioanna Mitroyanni and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008-10-13 with Law categories.
The creation of a group taxation framework to subject affiliated entities resident in more than one EC Member State to a single set of rules is an experiment without precedent. Group taxation normally deals with tax liability in the context of a single jurisdiction. There is no system of group taxation worldwide which embraces more than one fiscal jurisdiction under a single regulatory umbrella. This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse. Among the topics covered. The relevant jurisprudential and legislative framework of the European Internal Market; A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers; The policies for corporate taxation in integrated markets; Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability; Tests for entitlement to group membership; Tax base integration; - Territorial delineation of the group; and Formulary apportionment. In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.
International And Ec Tax Aspects Of Groups And Companies
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Author : Guglielmo Maisto (jurist.)
language : en
Publisher: IBFD
Release Date : 2008
International And Ec Tax Aspects Of Groups And Companies written by Guglielmo Maisto (jurist.) and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Corporations categories.
Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.
The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes
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Author : Bruno da Silva
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-07-11
The Impact Of Tax Treaties And Eu Law On Group Taxation Regimes written by Bruno da Silva and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2016-07-11 with Law categories.
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.
From Marks And Spencer To X Holding
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Author : Dennis Weber
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2011-08-03
From Marks And Spencer To X Holding written by Dennis Weber and has been published by Kluwer Law International B.V. this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011-08-03 with Law categories.
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.
The Final Report Of The Worldwide Unitary Taxation Working Group
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Author : United States. Department of the Treasury. Worldwide Unitary Taxation Working Group
language : en
Publisher:
Release Date : 1984
The Final Report Of The Worldwide Unitary Taxation Working Group written by United States. Department of the Treasury. Worldwide Unitary Taxation Working Group and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1984 with Corporations, Foreign categories.
Taxation Of Corporate Groups
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Author : Miguel Correia
language : en
Publisher:
Release Date : 2013
Taxation Of Corporate Groups written by Miguel Correia and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with Corporations categories.
This book proposes an interdisciplinary and comparative approach to the taxation of corporate groups. Chapter 1 analyses the core mechanical pillars of corporate income tax (CIT) systems and their impact on corporate behaviour. Chapter 2 first analyses the economic, legal and functional nature of corporate groups. Then, it examines the fundamental mechanical operation of CIT systems assuming that no tax integration solution, such as group taxation or flow-through taxation, is applicable, and assesses the merits and shortfalls of taxing corporate groups in this manner. Conversely, in chapter 3 the book analyses how corporate groups may be taxed under tax integration solutions and investigates the consequences of adopting such a stance. The study concludes, in chapter 4, by proposing a set of policy guidelines that should be considered when approaching the taxation of corporate groups.
International Company Taxation
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Author : Ulrich Schreiber
language : en
Publisher: Springer Science & Business Media
Release Date : 2013-01-30
International Company Taxation written by Ulrich Schreiber and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-01-30 with Business & Economics categories.
The book is written for students of business economics and tax law. It focuses on investment and financing decisions in cross-border situations. In particular, the book deals with: Legal structures of international company taxation, International double taxation, Source-based and residence-based income taxation, International investment and profit shifting, International corporate tax planning, International tax planning and European law, Harmonization of corporate taxation in the European Union, International tax planning and tax accounting. International tax law is designed to avoid international double taxation and to combat international tax avoidance. Nevertheless, companies investing in foreign countries may suffer from international double taxation of profits. On the other hand, these companies may also be able to exploit an international tax rate differential by means of cross-border tax planning. Ulrich Schreiber holds the chair of Business Administration and Business Taxation at the University of Mannheim. He serves as co-editor of Schmalenbachs Zeitschrift für betriebswirtschaftliche Forschung (zfbf) and Schmalenbach Business Review (sbr) and is affiliated with the Centre for European Economic Research (ZEW) as a research associate. Ulrich Schreiber is a member of the Academic Advisory Board of the Federal Ministry of Finance.
International Company Taxation In The Era Of Information And Communication Technologies
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Author : Anne Schäfer
language : en
Publisher: Springer Science & Business Media
Release Date : 2007-12-18
International Company Taxation In The Era Of Information And Communication Technologies written by Anne Schäfer and has been published by Springer Science & Business Media this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007-12-18 with Business & Economics categories.
Anne Schäfer presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.
Group Taxation
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Author : International Fiscal Association. Congress
language : de
Publisher:
Release Date : 2004
Group Taxation written by International Fiscal Association. Congress and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004 with Taxation categories.