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Author: Ernesto Crivelli Publisher: International Monetary Fund ISBN: 1513570765 Category : Business & Economics Languages : en Pages : 61
Book Description
This paper aims to contribute to the European policy debate on corporate income tax reform in three ways. First, it takes a step back to review the performance of the CIT in Europe over the past several decades and the important role played by MNEs in European economies. Second, it analyses corporate tax spillovers in Europe with a focus on the channels and magnitudes of both profit shifting and CIT competition. Third, the paper examines the progress made in European CIT coordination and discusses reforms to strengthen the harmonization of corporate tax policies, in order to effectively reduce both tax competition and profit shifting.
Author: Ernesto Crivelli Publisher: International Monetary Fund ISBN: 1513570765 Category : Business & Economics Languages : en Pages : 61
Book Description
This paper aims to contribute to the European policy debate on corporate income tax reform in three ways. First, it takes a step back to review the performance of the CIT in Europe over the past several decades and the important role played by MNEs in European economies. Second, it analyses corporate tax spillovers in Europe with a focus on the channels and magnitudes of both profit shifting and CIT competition. Third, the paper examines the progress made in European CIT coordination and discusses reforms to strengthen the harmonization of corporate tax policies, in order to effectively reduce both tax competition and profit shifting.
Author: Carsten Wendt Publisher: Springer Science & Business Media ISBN: 3834981931 Category : Business & Economics Languages : en Pages : 247
Book Description
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.
Author: Lorraine Eden Publisher: University of Toronto Press ISBN: 9780802007766 Category : Business & Economics Languages : en Pages : 788
Book Description
Eden examines how transfer pricing has been handled in different disciplines, including international business, economics, accounting, law and public policy.
Author: Ruud A. de Mooij Publisher: International Monetary Fund ISBN: 1513511777 Category : Business & Economics Languages : en Pages : 388
Book Description
The book describes the difficulties of the current international corporate income tax system. It starts by describing its origins and how changes, such as the development of multinational enterprises and digitalization have created fundamental problems, not foreseen at its inception. These include tax competition—as governments try to attract tax bases through low tax rates or incentives, and profit shifting, as companies avoid tax by reporting profits in jurisdictions with lower tax rates. The book then discusses solutions, including both evolutionary changes to the current system and fundamental reform options. It covers both reform efforts already under way, for example under the Inclusive Framework at the OECD, and potential radical reform ideas developed by academics.
Author: Rolf Eicke Publisher: Kluwer Law International B.V. ISBN: 9041127941 Category : Law Languages : en Pages : 526
Book Description
The book deals with tax planning with holding companies located in Europe, Asia of the Caribbean. It analyses the problem of repatriating U.S. profits from Europe, going far beyond the routing of income via different companies. Instead, the approach includes an analysis of the interdependencies between international tax competition, holding company regimes, and tax planning concepts in order to establish a basis for tax planning measures regardless of the fast changing legal environment for holding companies in the different countries.
Author: Jérôme Monsenego Publisher: IBFD ISBN: 9087221134 Category : Business enterprises, Foreign Languages : en Pages : 415
Book Description
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.
Author: Dennis Weber Publisher: Kluwer Law International B.V. ISBN: 9041134786 Category : Law Languages : en Pages : 248
Book Description
Group taxation – special schemes according to which a group of companies meeting certain requirements may be assimilated for tax purposes to a single company – exists in several European Member States and is now under consideration in an EU proposal concerning a common consolidated corporate tax base (CCCTB). Its rationale as a potential EU tax regime has arisen from a series of high-profile ECJ cases concerning cross-border tax relief claims – decisions which have been criticized for lack of clarity and for breach of freedom of establishment (Article 49 TFEU). Group taxation has now become one of the most intensively debated issues in EU tax law. The papers collected in this timely book derive from an ACTL Seminar held at Amsterdam in April 2010. The thirteen authors are either well-known practitioners from major law firms and accounting firms, or noted European tax scholars, or both. Among the central issues covered in the book are the following: the underlying tax obstacles which exist for companies operating in more than one Member State; potential for tax avoidance; prevention of double use of losses (the ‘no possibilities’ test); disadvantages that arise as a consequence of the parallel exercise of fiscal sovereignty; the concept of ‘balanced allocation of taxing powers’; meaning of ‘final losses’; the ‘Bosal fix’; cash-flow disadvantages of having to carry losses forward; deduction of currency losses; deduction-and-recapture rules; and VAT grouping.
Author: Lothar Lammersen Publisher: Springer Science & Business Media ISBN: 3790816167 Category : Business & Economics Languages : en Pages : 256
Book Description
The tax burden on investment or companies is an important factor for the attractiveness of a country or a region. In particular, business location and investment decisions are influenced by the relative tax burdens encountered in different regions. This study presents estimates of the effective average and marginal tax rates on company investment for 143 regions in Europe and the USA. Using the approach pioneered by Michael Devereux and Rachel Griffith, it is shown that companies face a wide variation of effective tax burdens across European regions. The results are explained by analysing the importance of specific tax provisions for the tax burden at the various locations.
Author: Joann Martens-Weiner Publisher: Springer Science & Business Media ISBN: 0387294872 Category : Business & Economics Languages : en Pages : 127
Book Description
Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.
Author: Ernesto Crivelli
Author: Ernesto Crivelli
Author: Carsten Wendt
Author: Lorraine Eden
Author: Ruud A. de Mooij
Author: Rolf Eicke
Author: Jérôme Monsenego
Author: International Bureau of Fiscal Documentation
Author: Dennis Weber
Author: Lothar Lammersen
Author: Joann Martens-Weiner