The Determination Of Corporate Taxable Income In The Eu Member States
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The Determination Of Corporate Taxable Income In The Eu Member States
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Author : Dieter Endres
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2007-01-01
The Determination Of Corporate Taxable Income In The Eu Member States written by Dieter Endres 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 2007-01-01 with Law categories.
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.
Common Corporate Tax Base Cc C Tb And Determination Of Taxable Income
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Author : Christoph Spengel
language : en
Publisher: Springer Science & Business Media
Release Date : 2012-03-13
Common Corporate Tax Base Cc C Tb And Determination Of Taxable Income written by Christoph Spengel 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 2012-03-13 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.
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.
The Eu Common Consolidated Corporate Tax Base
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Author : Dennis Weber
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2016-04-24
The Eu Common Consolidated Corporate Tax Base 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 2016-04-24 with Law categories.
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.
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.
Corporate Income Taxation In Europe
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Author : Michael Lang
language : en
Publisher: Edward Elgar Publishing
Release Date : 2013-10-31
Corporate Income Taxation In Europe written by Michael Lang 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 2013-10-31 with Law categories.
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
The European Union S Corporate Income Tax Policy
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Author : Pernille Stordrange
language : en
Publisher: GRIN Verlag
Release Date : 2012-05-29
The European Union S Corporate Income Tax Policy written by Pernille Stordrange and has been published by GRIN Verlag this book supported file pdf, txt, epub, kindle and other format this book has been release on 2012-05-29 with Political Science categories.
Seminar paper from the year 2012 in the subject Politics - International Politics - Topic: European Union, grade: A, BI Norwegian Business School (Public governance), course: EU Policy Process, language: English, abstract: In this paper I chronologically go through the policy process towards a harmonised corporate income tax in the EU member states. By using Jenkins-Smith and Sabatier's advocacy coalition framework (ACF) I evaluate how events internal and external to the EU, as well as policy-oriented learning have brought the process forward and caused policy change. I also explain how the lack of favourable conditions has caused stalemate and lack of progress. I find that changing socio-economic conditions have facilitated and hampered the policy process and that macroeconomic conditions have affected member states willingness to implement coordinating measures. Other determinants of change are internal developments in the EU such as enlargements, ECJ jurisprudence or change in political leadership. Over the time period under study, the European Commission, as the agenda-setter in the EU has learned from previous failures and new scientific information and altered its strategy along the way. Member states have also over time changed their view on the EU in general and corporate income tax harmonisation in particular. The outcome of the EC's efforts over the years has been varying, and the policy process has proceeded in fits and starts. So far, the EC has achieved some degree of coordination, but not harmonisation of corporate income tax systems. What the future brings depends on the variables discussed throughout the paper.
Taxation Trends In The European Union
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Author : Eurostat
language : en
Publisher:
Release Date : 2007
Taxation Trends In The European Union written by Eurostat and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2007 with Business & Economics categories.
This report contains a detailed statistical and economic analysis of the tax systems of the Member States of the European Union and Norway. The data are presented within a unified statistical framework (the ESA95 harmonised system of national and regional accounts), which makes it possible to assess the heterogeneous national tax systems on a fully comparable basis. The standard classifications of tax revenues (by major type of tax or by level of government) presented in most international tax revenue statistics are hard to interpret in economic terms. This publication stands out for offering a breakdown of tax revenues by economic function (i.e. according to whether they are raised on consumption, labour or capital). This classification is based on disaggregated tax data and on a breakdown of the revenue from the personal income tax. In addition, the report contains indicators of the average effective tax burden on consumption, labour and capital. Country chapters give an overview of the tax system in each of the 28 countries covered, the revenue trends and the main recent policy changes. Detailed tables allow comparison between the individual countries and European averages. Data cover the 1995-2005 period and are presented both as a percentage of GDP and as a percentage of total taxation.
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.
Credit Method Compatibility And Constraints Under Eu Law
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Author : Rita Julien
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2022-01-13
Credit Method Compatibility And Constraints Under Eu Law written by Rita Julien 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 2022-01-13 with Law categories.
As European Union (EU) Member States seek to counteract base erosion and profit shifting (BEPS) practices while avoiding new obstacles to the EU’s internal market such as double taxation, the credit method, also known as the foreign tax credit, is one of the essential tools in this balancing act, yet it is one that has given rise to various EU law challenges and questions. This invaluable book – the first in-depth study of the EU law constraints on designing the credit method – delineates the EU law boundaries within which the Member States must operate when they implement this method of tax relief. For the first time, the Court of Justice of the European Union (CJEU) cases that may affect, directly or indirectly, the credit method and its main components are systematically identified and analysed in order to extract the legal findings and principles that define the contours within which the Member States can manoeuvre when considering EU-compatible approaches to the credit method. To this end, among others, this book offers: an extensive study of the historical legal developments of the credit method; an overview of the key design features of the credit method, considering the optional, variable components, such as the credit limitation (maximum creditable amount), that tailor it to different legal and policy considerations; an analysis of the legal constraints on the key features of the credit method flowing from CJEU case law on the fundamental freedoms, considering the impact of landmark cases and concepts (e.g., Schumacker, neutralization); the EU law implications based on the type of credit method (direct, indirect, imputation) and the feature of the credit method (e.g., credit limitation, credit carryforward); and examples to clearly and concisely illustrate the basic operation of the credit method and some of the main calculation and EU law issues. The author’s doctoral dissertation, on which the book is based, was awarded the Wolfgang Gassner Science Prize 2020 and the European Doctoral Tax Thesis Award 2020. As a timely, comprehensive and practical study of the relationship between the credit method and EU law, this book will be welcomed by lawyers and other professionals working with taxation matters, as well as by tax policymakers and academics in the fields of international and European tax law.