Taxation Of Foreign Business Income Within The European Internal Market
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Taxation Of Foreign Business Income Within The European Internal Market
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Author : Jérôme Monsenego
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Foreign Business Income Within The European Internal Market written by Jérôme Monsenego and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Business enterprises, Foreign categories.
The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriality or on the principle of worldwide taxation, are in conflict with the objective of achievement of the internal market. This objective is indeed difficult to reach when it comes to the taxation of foreign income, given that the Member States are far from taxing companies doing business cross-border as if their operations were purely domestic. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation and the attribution of profits to permanent establishments. This dissertation analyses this conflict on the basis of a study of the case law of the European Court of Justice as well as some of the key provisions of the European treaties. It appears that both the fiscal principle of territoriality and the principle of worldwide taxation give rise to complex issues of compatibility with the law of the European Union. Although the analysis conducted throughout the dissertation provides some guidance for the taxation of the foreign business income of companies, it is concluded that the Court cannot, by itself, efficiently resolve the conflict between such taxation and the objective of achievement of the internal market.
Company Taxation In The Internal Market
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Author : European Commission
language : en
Publisher:
Release Date : 2002
Company Taxation In The Internal Market written by European Commission and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2002 with Business enterprises categories.
Analysis of problems in the field of company taxation in the Internal Market: the obstacles to cross-border economic activity and their possible remedies. This study (the major source document for the European Commission's policy statement on company taxation COM (2001) 582 also considers the possibilities for a reform of company taxation at EU level which would aim at providing companies with a single consolidated tax base for their EU-wide activities.
Taxation Of Investment Funds In The European Union
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Author : Tomi Viitala
language : en
Publisher: IBFD
Release Date : 2005
Taxation Of Investment Funds In The European Union written by Tomi Viitala and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Capital gains tax categories.
The book analyses the taxation of investment funds and their investors from the standpoint of domestic tax laws, tax treaties and EC law. It also provides a comprehensive understanding of the tax issues arising in the cross-border transactions of investment funds and private fund investors in the European Union. The viewpoints of the source state of income, residence state of the investment fund as well as the residence state of the investor are all considered. The book takes a comparative approach by covering five EU Member States (the United Kingdom, Germany, France, Luxembourg and Finland). On the basis of the examination at the Member State level, the present tax rules and practices are tested against the fundamental freedoms of the EC Treaty. The conclusion is that there are still various tax measures that are likely to be in conflict with EC law. The book also discusses possibilities of adopting targeted measures of positive integration at the level of the European Union with a view to enhancing the objective of the single investment fund market.
Free Movement And Tax Treaties In The Internal Market
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Author : Maria Hilling
language : en
Publisher: Iustus Forlag
Release Date : 2005
Free Movement And Tax Treaties In The Internal Market written by Maria Hilling and has been published by Iustus Forlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2005 with Law categories.
"This book deals with the impact of the free movement rules in the EC Treaty on tax treaties in the internal market. This is a highly relevant issue since a provision in breach of the free movement rules in inapplicable. The potential far-reaching consequences following the preclusion of tax treaty provisions makes it important for taxpayers and governments of the Member States of the EU to predict when a provision in a tax treaty may be in conflict with free movement law." "This book identifies the rights and obligations stemming from the free movement rules. As they are not very detailed, the case law is crucial. Hence, this book includes extensive case law studies, focusing primarily on cases where the Court of Justice of the European Communities (ECJ) has interpreted the free movement rules in relation to tax treaty provisions and unilateral income tax legislation. This study provides a systematization of such case law, highlighting consistencies and inconsistencies."--BOOK JACKET.
A Common Tax Base For Multinational Enterprises In The European Union
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Author : Carsten Wendt
language : en
Publisher: Springer Science & Business Media
Release Date : 2009-04-16
A Common Tax Base For Multinational Enterprises In The European Union written by Carsten Wendt 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 2009-04-16 with Business & Economics categories.
Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states.
Selectivity In State Aid Law And The Methods For The Allocation Of The Corporate Tax Base
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Author : Jérôme Monsenego
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2018-06-05
Selectivity In State Aid Law And The Methods For The Allocation Of The Corporate Tax Base written by Jérôme Monsenego 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 2018-06-05 with Law categories.
High profile cases before the European Commission and the EU courts have intensified scrutiny of the link between State aid law and the taxation of multinational enterprises. Certain decisions have raised questions about fiscal sovereignty and the interpretation of the rules on State aid – in particular the notion of selectivity, which have not been addressed in detail by existing research. The combination of the evolution of the notion of selectivity in State aid law, on the one hand, and the need to adapt the rules for the taxation of the profits of multinational enterprises to the modern economy, on the other hand, makes it necessary to assess whether existing as well as alternative rules for the allocation of the corporate tax base might entail a selective treatment. This book responds to the need of research in the area of State aid law applied to the taxation of the income of multinational enterprises, focusing on the crucial concept of selectivity. The analysis proceeds with a detailed investigation of the theoretical issues that arise when applying the selectivity test in State aid law to three methods for the allocation of the corporate tax base between the members of multinational enterprises: – the arm’s length principle; – transfer pricing safe harbours; and – systems of formula apportionment. This research project is conducted at a theoretical level, without considering national provisions or particular tax treaties. The author suggests an analytical framework on the application of the selectivity test to the three allocation methods. It is concluded that these methods are likely to have certain selective features, with varying possibilities to be justified by the inner logic of a corporate income tax system. It is also demonstrated that selectivity occurs for different reasons, due to the different rationales of the three allocation methods. This book is intended at contributing to the academic literature on the impact of State aid law on the principles for the taxation of the income of multinational enterprises. The outcome of this research project is also relevant for lawmakers who need to reconcile the imperatives of State aid law with the design of rules that match their tax policies, as well as for judges or lawyers who apply the rules on State aid to tax provisions.
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law
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Author : Guglielmo Maisto
language : en
Publisher: IBFD
Release Date : 2012
Taxation Of Intercompany Dividends Under Tax Treaties And Eu Law written by Guglielmo Maisto and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012 with Corporations categories.
This book is a detailed and comprehensive study on the taxation of cross-border dividend distributions. It first considers cross-border dividend taxation in the context of EU law. In this field, issues such as the jurisprudence of the European Court of Justice, the hindrance to the internal market caused by double taxation of dividends and the compatibility of dividend withholding taxes are dealt with. Next, the book discusses the taxation of dividends under tax treaties, in particular focusing on the definition of "dividends" in the OECD Model Convention and the meaning of the concept of "beneficial owner" as applied to dividends. The application of domestic and agreement-based anti-abuse rules to dividends is thoroughly analysed. Finally, the relevance of the non-discrimination provision enshrined in Art. 24 of the OECD Model Convention to dividends as well as procedural issues relating to treaty relief and possible ways of improvement are taken into consideration. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and non-European jurisdictions.
Integration Approaches To Group Taxation In The European Internal Market
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Author : Ioanna Mitroyanni
language : en
Publisher:
Release Date : 2008
Integration Approaches To Group Taxation In The European Internal Market written by Ioanna Mitroyanni and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2008 with Business enterprises categories.
This work explores the prospect for creating a group taxation system extending across national borders in the EC. The author discusses what shape the elements of such a system should take and identifies the areas of complexity or probable impasse. The followig topisc are covered: ECJ jurisprudence relevant to groups; corporate tax systems of Canada, Switzerland and the USA with a focus on differences between the federal and sub-federal level; the policies for corporate taxation in integrated markets; administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability; entitlement to group membership; tax base integration; territorial delineation of the group; and formulary apportionment.
Tax Based Eu Own Resources
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Author : Philippe Cattoir
language : en
Publisher:
Release Date : 2004
Tax Based Eu Own Resources written by Philippe Cattoir and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2004 with Income tax categories.
Recoge: 1.Introduction - 2.Criteria for the assessment of EU taxes - 3.Possible EU taxes - 4.Comparasion and overall assessment - 5.Conclusions.
European Tax Integration
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Author : Pasquale Pistone
language : en
Publisher:
Release Date : 2018
European Tax Integration written by Pasquale Pistone and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2018 with Taxation categories.
This book focuses on the status quo of European tax integration, combining law, policy and politics. Good policy should identify and address problems when they arise, achieving suitable solutions that law implements. Within the European Union, this relation is malfunctioning or entirely missing in direct tax matters. Positive tax integration in the European Union has mostly failed to transform supranational policy goals into actual measures of harmonization and coordination, except for the recent reaction to tax avoidance. The topical studies contained in this book hold that without a proper action that removes cross-border tax obstacles, positive tax integration shifts away from its original goals. Furthermore, such a scenario leaves the bulk of European tax integration in the hands of the limits established by negative tax integration, with little room for developing a structured policy in the interest of the European Union. This peer-reviewed publication aims to stimulate debate among scholars, decision-makers, practitioners, politicians and interpreters of European international tax law, with a view to bringing European tax integration back on the right track.