Withholding Taxation In The Eu
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Withholding Taxation In The Eu
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Author : Florian Haase
language : en
Publisher: Edward Elgar Publishing
Release Date : 2023-12-11
Withholding Taxation In The Eu written by Florian Haase 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 2023-12-11 with Law categories.
Florian Haase presents a comprehensive overview of the general mechanisms by which taxation is withheld in Europe and explores their practical implications. He expertly navigates the complexities of international tax law and provides a rigorous examination of the challenges currently facing this area of legislation, including tax evasion and avoidance, double taxation, and tax treaties.
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.
Withholding Taxes And The Fundamental Freedoms
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Author : Karin Simader
language : en
Publisher:
Release Date : 2013
Withholding Taxes And The Fundamental Freedoms written by Karin Simader and has been published by this book supported file pdf, txt, epub, kindle and other format this book has been release on 2013 with Capital movements categories.
In many recent judgments the European Court of Justice (ECJ) has tested the withholding tax regimes of Member States against the fundamental freedoms. In this book, the first systematic review of these judgments in the light of other ECJ case law and legal doctrine, the author's prodigious research has engendered a remarkably complete answer to the question of the extent to which EU Member States are allowed to levy withholding taxes, particularly on payments to non-residents. The book shows how the fundamental freedoms interfere with national tax laws' withholding tax regimes, and suggests informed and insightful answers to questions not yet clarified by the ECJ. The scope of treatment goes beyond the TFEU to the EEA Agreement, various agreements with Switzerland, and a number of association and partnership agreements with third countries. The focus remains fixed on the instrument of a withholding tax as such, not with individual countries or types of income. Rather, the common features of withholding taxes on any kind of income are highlighted, so practitioners have a guide that can be used definitively across the widest possible range of withholding tax situations. --
Eu Freedoms Non Eu Countries And Company Taxation
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Author : D.S. Smit
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2012-06-01
Eu Freedoms Non Eu Countries And Company Taxation written by D.S. Smit 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 2012-06-01 with Law categories.
In today’s environment of largely globalizing national economies, international economic integration does not stop at the frontiers of the European Union. Many non-EU-based enterprises are carrying on business in the European Union through the operation of branches or subsidiaries established in EU Member States, and a large number of EU-based enterprises maintain a diversified range of investments outside the Union. Accordingly, in both inward and outward investment relationships, ‘economic openness’ is key nowadays. This legal relationship between EU Member States and the EU as a whole vis-à-vis the rest of the world is the starting point of this book. The author analyses the ‘freedom of investment’ concept between EU Member States and non-EU States under EU law, and specifically its effect on company taxation regimes, from the perspective of multinational enterprises. Focusing on the impact of the Treaty freedoms and international integration agreements on relations with non-EU Member States, this work is the first to specifically address the all-important issue: Under which circumstances can investment-related rights deriving from EU law be invoked by companies established in non-EU states? The analysis identifies the impact of the EU Treaty freedoms on six basic corporate income tax themes that are of particular interest for multinational enterprises: limitation on the deduction of interest expenses; withholding taxes on dividend, interest, and royalty payments; relief for double taxation of income received from foreign investments; CFC legislation; non-deduction of foreign losses from the domestic taxable base; and company taxation upon the transnational transfer of business assets.
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.
Introduction To European Tax Law On Direct Taxation
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Author : Michael Lang
language : en
Publisher: Linde Verlag GmbH
Release Date : 2022-08-25
Introduction To European Tax Law On Direct Taxation written by Michael Lang and has been published by Linde Verlag GmbH this book supported file pdf, txt, epub, kindle and other format this book has been release on 2022-08-25 with Law categories.
Basic knowledge of European Tax Law This concise handbook has become a traditional instrument for gaining basic knowledge of European tax law with emphasis on direct taxes. It is directed at students, experienced international tax specialists with little knowledge of European law, European law specialists and non-Europeans who deal with Europe for business or academic reasons and need to understand the foundations of European tax law. Moreover, this book can be useful to academics without a legal background in approaching technical issues raised by European Union tax law, as well as give inspiration to the most experienced European direct tax law experts. This seventh edition further refines and updates the content, but also enhances the coordination across the chapter and the selection of case law in line with the weight that it carries for the development of European tax law. An indispensable consultation tool - Introduction to European Tax Law on Direct Taxation.
Taxation Of Cross Border Dividends Paid To Individuals From An Eu Perspective
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Author : Erwin Nijkeuter
language : en
Publisher: Kluwer Law International B.V.
Release Date : 2012-08-01
Taxation Of Cross Border Dividends Paid To Individuals From An Eu Perspective written by Erwin Nijkeuter 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 2012-08-01 with Law categories.
This book is the first in-depth study to analyze the circumstances in which the freedom of establishment or free movement of capital may apply to the cross-border distribution of dividends. It covers both the positive integration set forth by the European Commission and the Member States and the negative integration developed by the European Court of Justice. The author discusses such elements of these integration measures as the following: economic double taxation (two different subjects pay tax on the same profit); juridical double taxation (two different states tax one and the same person for the same income); exemption, credit, and other techniques adopted by States to avoid double taxation; division of taxing rights between two States with respect to dividend income; prevention of juridical double taxation by bilateral tax conventions; Member States’ mitigation of economic double taxation; double exemption as an unplanned outcome of double taxation prevention measures; and order of precedence between freedom of establishment and free movement of capital. The analysis treats relevant provisions the OECD Model Tax Convention in detail, as this model is widely used by national tax authorities in connection with international taxation of dividends. It also examines pertinent initiatives launched by the European Commission up to and including its consultation paper of January 28, 2011. In addition to its scrutiny of the disparities in cross-border dividend taxation within the European Union, this book stands out for its detailed coverage of the progress made in resolving these challenging taxation issues. It is sure to be welcomed by investors, corporate counsel, and national revenue authorities.
Eu Tax Law
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Author : Marjaana Helminen
language : en
Publisher: IBFD
Release Date : 2011
Eu Tax Law written by Marjaana Helminen and has been published by IBFD this book supported file pdf, txt, epub, kindle and other format this book has been release on 2011 with Direct taxation categories.
This book deals with all the EC law norms that are relevant from the perspective of direct taxes. It explains how these norms are, and should be, interpreted and how they affect national tax laws and the tax treatment in EU Member States. It begins by giving a comprehensive overview of the basic principles and concepts of EC tax law and all relevant articles of the EC Treaty, analysing them in the light of direct tax case law. A discussion follows covering all relevant EC directives and recommendations and other soft law material on direct taxes. Reference is made to all relevant judgments of the EC Court on direct taxes. The book includes a chapter on the tax treatment of the different EU entity forms and the future of corporate taxation, with a separate chapter dedicated to the EC law issues related to transfer pricing and to the EC law norms on administrative assistance in tax matters.
European Union Corporate Tax Law
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Author : Christiana H. J. I. Panayi
language : en
Publisher: Cambridge University Press
Release Date : 2021-06-17
European Union Corporate Tax Law written by Christiana H. J. I. Panayi 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 2021-06-17 with Law categories.
How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book 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. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.
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