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Author: Christoph Spengel Publisher: Springer Science & Business Media ISBN: 3642284337 Category : Law Languages : en Pages : 130
Book Description
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.
Author: Christoph Spengel Publisher: Springer Science & Business Media ISBN: 3642284337 Category : Law Languages : en Pages : 130
Book Description
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.
Author: Dennis Weber Publisher: Kluwer Law International B.V. ISBN: 9041192689 Category : Law Languages : en Pages : 272
Book Description
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.
Author: Publisher: ISBN: Category : Languages : en Pages :
Book Description
The European Commission is currently working on a legislative draft to harmonise the corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a Common Consolidated Corporate Tax Base (CCCTB) applicable for multinational companies. As the EU member states are not willing to surrender their taxing power to the supranational level of the EU each group entity2s tax base would be determined by apportionment of the group2s overall taxable income according to a predefined micro-economic factor based formula whereas the group income will be calculated by consolidating earnings beforehand separately determined by each group entity (preconsolidation income). The situs state of the particular group entity would then apply its statutory corporate tax rate on the apportioned tax base. This paper evaluates the effects of this prospective apportionment procedure on any given corporate group entity and finds that the share of the group2s income allocated to a particular entity using the apportionment formula does regularly not equal the pre-consolidation income of the respective group entity. The reasons for this regular observable deviation can be found on the one hand in the concept of the apportionment formula and on the other hand in the specifics of the definitions of the apportionment factors. (author's abstract).
Author: Malcolm Gammie Publisher: CEPS ISBN: 9290795999 Category : Business & Economics Languages : en Pages : 137
Book Description
"This report offers a positive assessment of the basic compatibility of IFRS and tax principles. It also provides constructive information and guidance to the European Commission to identify the elements of member states' tax systems that must be considered to achieve convergence to a CCCTB from the starting point of IFRS. The Task Force also emphasises, however, that a common corporate tax base among member states is not enough. Any CCCTB should be compatible with the EU's Lisbon objectives. And to meet those objectives, there needs to be a single common tax base with consolidation and allocation, in a form that is competitive, efficient and flexible."--BOOK JACKET.
Author: Shu-Chien Chen Publisher: ISBN: Category : Languages : en Pages : 36
Book Description
Common Consolidated Corporate Tax Base (CCCTB) is an ambitious tax reform project under EU law, to harmonize corporate income tax base on a group basis at the EU level, and use a pre-determined formulary apportionment mechanism (i.e. a formula consisting the sales factor, the asset factor and the labour factor) to allocate taxing rights between EU Member States. The standard formula is based on the business model of the manufacturing industry and is not completely suitable for the financial industry. The current CCCTB Proposal has a special formula apportioning pan-EU taxable income a multinational taxpayer in the financial industry but there are some problems in it. This paper compares the financial industry formula in the USA state taxation and argues that, the role of the monetary capital is the key criterion to design the financial industry formula under the CCCTB. Based on this rationale, the financial industry formula should include a special rule for the asset factor to include the financial assets and a special rule for the sales factor. Such formula would be suitable not only to multinational groups consisting of pure financial institutions but also to multinational groups consisting of both financial and non-financial institutions.
Author: Yariv Brauner Publisher: Kluwer Law International B.V. ISBN: 9041141987 Category : Law Languages : en Pages : 355
Book Description
Virtually all objections to taxation schemes spring from perceptions of unfairness. Is tax fairness possible? The question is certainly worth investigating in depth, and that is the purpose of this book. Today, as governments are busily making new tax rules in the wake of staggering budget deficits, is perhaps an appropriate time to pay heed to fairness so it can be incorporated as far as possible into tax reform. With twelve contributions from some of the world’s most respected international tax experts—including the late Paul McDaniel, in whose honor these essays were assembled—this invaluable book focuses on tax expenditure analysis, the quest for a just income tax, and division and/or harmonization of the income tax base among jurisdictions. Among the areas of taxation ripe for reform from a fairness point of view the authors single out the following: tax expenditure budget construction; tax expenditure reporting; modern welfare economics as a driver of tax reform; grantor trust rules; the notion of “horizontal equity”; the international tax norm of “income source”; transfer pricing; and jurisdictional application of VAT. Specific ongoing reforms in the United States, Australia, and other countries—as well a detailed analysis of the EU’s proposed common consolidated corporate tax base (CCCTB)—are also examined for fairness. As a timely, high-quality resource that effectively tackles an array of salient issues, this is a book that will be read and studied by tax practitioners, corporate tax experts, government tax policy makers, advisers and consultants on the reform and design of tax systems, and international organizations involved in standard setting related to tax administration, as well as academics and researchers.
Author: Richard L. Doernberg Publisher: Aspen Publishers ISBN: Category : Business & Economics Languages : en Pages : 776
Book Description
A return to coverage of partnerships & limited liability companies highlights the Third Edition of FEDERAL INCOME TAXATION OF CORPORATIONS AND PARTNERSHIPS. With more of the extremely effective problems that gained it such widespread praise, this flexible casebook is now completely updated for use in a wide variety of course offerings. To simplify the intricacies of the taxation of business enterprises, the authors: use problems & examples in almost every chapter -in addition to cases & notes illustrate typical commercial transactions emphasize major themes of policy & practice keep the book flexible enough to be used in two-, three-, or four-credit courses offer an extensive Teacher's Manual FEDERAL INCOME TAXATION OF CORPORATIONS AND PARTNERSHIPS, Third Edition, is logically organized into three main parts: Corporations S Corporations Partnerships The Third Edition reflects recent developments in corporate & partnership taxation: 10 full chapters on partnership taxation including new materials that address the explosive growth of limited liability companies & hybrid entities new debt/equity limitations in corporate formations & reorganizations anti-abuse redemption provisions covering stock options & sales between related corporations the Anti-Morris Trust changes to tax-free spin-offs new elective classification regulations liberalization of Subchapter S shareholder restrictions & changes to timing of Subchapter S distributions, & Qualified Subchapter S Subsidiaries Give your students a firm foundation in the means & methods of corporate taxation & partnership today.
Author: Christiana HJI Panayi Publisher: Cambridge University Press ISBN: 1107354986 Category : Law Languages : en Pages : 413
Book Description
How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This unique study 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. Existing legislation, soft-law and the case-law of the Court of Justice are examined. The proposed CCCTB Directive and its potential application through enhanced co-operation are also considered. In addition to the tax issues pertaining to direct investment, the author examines the taxation of passive investment income, corporate reorganisations, exit taxes and the restrictive effect of domestic anti-abuse regimes. By doing so, the convergences and divergences arising from the interplay of EU corporate tax law and international tax law, especially the OECD model, are uncovered and highlighted.
Author: Christoph Spengel
Author: Christoph Spengel
Author: Dennis Weber
Author: 
Author: Malcolm Gammie
Author: Christian Valenduc
Author: Shu-Chien Chen
Author: Yariv Brauner
Author: Richard L. Doernberg
Author: Christiana HJI Panayi
Author: