Survey Of The Implementation Of The Ec Corporate Tax Directives
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Survey Of The Implementation Of The Ec Corporate Tax Directives
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Author : W. F. G. Wijnen
language : en
Publisher:
Release Date : 1995
Survey Of The Implementation Of The Ec Corporate Tax Directives written by W. F. G. Wijnen and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 1995 with Business & Economics categories.
Divided into two sections, this survey examines the Merger Directive and the Parent-Subsidiary Directive. The implementation of the directives is covered country-by-country. Each situation is applied to each country and is then analysed in detail, giving a complete picture of all permutations. Each country chapter concludes with a summary of all aspects of national law which could be in conflict with the Directives. Includes the 12 "older" EU countries.
Corporate Taxation Group Debt Funding And Base Erosion
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Author : Gianluigi Bizioli
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2020-02-07
Corporate Taxation Group Debt Funding And Base Erosion written by Gianluigi Bizioli 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 2020-02-07 with Law categories.
The EU’s Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. Specific issues and topics covered include the following: relation with the OECD’s Base Erosion and Profit Sharing project (BEPS) and the EU’s Common Corporate Tax Base initiative; technical subjects relating to corporate taxation and debt funding; problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; exclusion clauses for interest expenses; and interplay between interest limitation rules and anti-hybrid rules. A comparative analysis of implementation issues in four leading Member States—Germany, Italy, Spain and The Netherlands—as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD. This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.
Common Corporate Tax Base Cc C Tb And Determination Of Taxable Income
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Author : Christoph Spengel
language : en
Publisher: Springer
Release Date : 2012-03-16
Common Corporate Tax Base Cc C Tb And Determination Of Taxable Income written by Christoph Spengel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-03-16 with Law categories.
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.
Common Corporate Tax Base Cc C Tb And Determination Of Taxable Income
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Author : Christoph Spengel
language : en
Publisher: Springer
Release Date : 2012-03-24
Common Corporate Tax Base Cc C Tb And Determination Of Taxable Income written by Christoph Spengel and has been published by Springer this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-03-24 with Law categories.
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.
Eu Corporate Law And Eu Company Tax Law
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Author : Luca Cerioni
language : en
Publisher: Edward Elgar Publishing
Release Date : 2007-01-01
Eu Corporate Law And Eu Company Tax Law written by Luca Cerioni and has been published by Edward Elgar Publishing this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007-01-01 with Law categories.
With the European Union striving to become the world's most competitive economy, the developments in the two closely interconnected areas of European corporate law and European company tax law are of utmost importance. This book focuses on the crucial issues raised by these developments, on their far-reaching implications and on the key challenges to the future legislative choices. The book illustrates the key developments in EU corporate law and EU company tax law, the EU planned initiatives in these areas, and - at a time when member states increasingly tend to use company law and company tax provisions to attract businesses and investments - it suggests how future developments can contribute to the undistorted functioning of the internal market and to the strategic 'Lisbon-objective'. The explanation of these legislative and case-law developments is of use to students and indicates new opportunities for business expansion strategies throughout the European Community. The book concludes that new optional, but attractive, EU company law vehicles and company tax regimes would be, in these two areas, the only legal and effective means towards an undistorted functioning of the internal market and towards the Lisbon-objective. This ultimately gives rise to a far-reaching challenge for all debates on the future patterns of European integration. Luca Cerioni introduces new themes for academic research and discussion subjects for decision-makers and at the same time, uniquely, makes these accessible to a much wider international public of students, businesses and practitioners.
Doppelbesteuerungsabkommen
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Author : W. Gassner
language : en
Publisher: Kluwer Law International B.V.
Release Date : 1997-10-15
Doppelbesteuerungsabkommen written by W. Gassner 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 1997-10-15 with Business & Economics categories.
This collection of essays examines the effects of primary European Community Law on tax treaties concluded by the Member States.
The European Union And Direct Taxation
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Author : Luca Cerioni
language : en
Publisher: Routledge
Release Date : 2015-06-05
The European Union And Direct Taxation written by Luca Cerioni and has been published by Routledge this book supported file pdf, txt, epub, kindle and other format this book has been release on 2015-06-05 with Law categories.
Within the European Union, direct taxation is an area which often provokes controversy due to tensions between the tax sovereignty of the individual Member States and the desire for an integrated internal market. This book offers a critical review of the legislative and case-law developments in this area at the EU level, and reviews the European Commission’s proposed solutions in light of their concerns regarding the proper functioning of the EU’s internal market. Luca Cerioni set out a series of benchmarks determined from the objectives expressed by the European Commission, including: the elimination of double taxation and double non-taxation; the simplification of cross-border tax compliance; the reduction of abusive forum-shopping practices and general aggressive tax planning strategies; legal certainty for all businesses and individuals carrying on activities and receiving income in more than one EU Member State. Cerioni uses these benchmarks to ask which Directives and/or rulings have left legal uncertainty, and which have ended up creating or increasing the scope for aggressive tax planning. The book puts forward a comprehensive solution for a new optimal regime relating to tax residence, which would contribute to the EU project to the mutual benefit of Member States and taxpayers. As a thorough and critical discussion of EU tax rules in force, and of the European Court’s case law in direct taxation, this book will be of great use to academic researchers and students of EU law, tax practitioners, and policy-makers at the EU and national level.
Comparative Law Yearbook Of International Business
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Author : Dennis Campbell
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2003-12-01
Comparative Law Yearbook Of International Business written by Dennis Campbell 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 2003-12-01 with Law categories.
The 2003 volume of the Comparative Law Yearbook of International Business deals with a variety of topics in the field of commercial law. These range from mergers in Nigeria and joint ventures in Thailand and Hungary to the fight against corruption on an international level, as well as corporate fraud in the United States, with attention being focused upon the new Sarbanes-Oxley Act of 2002. Some authors have dealt with subjects that involve finance, such as foreign investment in e-commerce in China, employees' stock purchases and option plans in the United States, pension funds in Nigeria and preferential tax regimes in Madeira. There is also a review of the Agreement on Trade-Related Investment Measures. Other popular areas of commercial law that are covered in this volume include consumer protection in Bulgaria and alternative dispute resolution. Arbitration in Paraguay is discussed, along with the conducting of mediation by legal professionals. In addition, European Union law arises in relation to the likelihood of association, with another chapter detailing the economic association between Mexico and the European Union. The Commentators in this book are leading professionals in their respective fields and the interesting mix of topics should be of value to those involved in business in the international arena and their legal advisers.
The Politics Of Corporate Taxation In The European Union
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Author : Claudio Radaelli
language : en
Publisher: Routledge
Release Date : 2013-01-11
The Politics Of Corporate Taxation In The European Union written by Claudio Radaelli and has been published by Routledge this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013-01-11 with Business & Economics categories.
This study explores the formation of the European Union's tax policy and asks why member states did not raise objections to it. The author's analysis is enriched by two further levels of inquiry. Firstly, he examines the 'Europeanization' of domestic tax policy in Italy and the UK, asking how domestic policy has changed and what is meant by 'Europeanization'. Secondly, he puts the European Union tax policy in the wider context of tax globalization. Will the liberalization of capital movement, tax havens and the flexibility of multinationals in managing their taxable incomes wreck the European Union's fragile tax policies?
Cross Border Mergers Within The Eu
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Author : Harm Van den Broek
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2011-11-25
Cross Border Mergers Within The Eu written by Harm Van den Broek 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 2011-11-25 with Law categories.
As a result of the Regulation on the European Company and the Tenth Council Directive, all Member States are obliged to finally implement the merger arrangements of the 1990 Fiscal Merger Directive, forcefully raising the question of the tax consequences of cross-border mergers. This book is the first to focus in such an extended way on the meaning of the 1990 Directive’s tax provisions in this context. With unique and valuable insights drawn from legislative history documents never examined before, its detailed commentary leads to sound and practical recommendations on cross-border mergers within the EU from a tax law perspective. This book also examines to what extent taxation as a result of mergers is in line with the freedom of establishment and the free movement of capital. Clearly analysing the dangers of advance taxation, double taxation, double non taxation, and additional tax claims as a result of a merger, the book deals with such core elements as the following: the aims of cross-border merger relief schemes; the aims of cross-border merger relief schemes; transfer of losses; exit taxation; taxation of dividend withholding tax; employee participation rights; tax standing of creditors of a transferring company; and taxation of foreign shareholders. With its new insights on tax aspects of mergers within the European Union, this book will be of special value to merging companies and their shareholders, to tax administrations and courts, and to legislators who must properly implement the Merger Directive.