Taxation Of Foreign Business Income Within The European Internal Market PDF Download
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Author | : Jérôme Monsenego |
Publisher | : IBFD |
Total Pages | : 415 |
Release | : 2012 |
Genre | : Business enterprises, Foreign |
ISBN | : 9087221134 |
Download Taxation of Foreign Business Income Within the European Internal Market Book in PDF, ePub and Kindle
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 | : Carsten Wendt |
Publisher | : Springer Science & Business Media |
Total Pages | : 247 |
Release | : 2009-04-16 |
Genre | : Business & Economics |
ISBN | : 3834981931 |
Download A Common Tax Base for Multinational Enterprises in the European Union Book in PDF, ePub and Kindle
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 | : European Commission |
Publisher | : |
Total Pages | : 804 |
Release | : 2002 |
Genre | : Business enterprises |
ISBN | : |
Download Company Taxation in the Internal Market Book in PDF, ePub and Kindle
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.
Author | : M.F. de Wilde |
Publisher | : |
Total Pages | : |
Release | : 2020 |
Genre | : |
ISBN | : |
Download On the Future of Business Income Taxation in Europe Book in PDF, ePub and Kindle
How should Europe respond to society's calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the CCTB/CCCTB draft directives into a new system of international taxation, i.e. a unitary taxation model for taxing the worldwide economic profits of multinationals, using a destination-based apportionment formula (CCCTB 2.0) to apportion the tax base to countries both within and outside the European Union. Under such a system, it would be up to the EU Member States themselves to determine the rate applying to the tax base apportioned to them. This would take tax out of the equation in the case of marginal financing and investment decisions, while also curtailing its influence on investment location decisions and, at the same time, making 'gaming the system' more difficult. EU Member States would, in turn, regain their autonomy to set their corporate tax rates at the levels they regard as appropriate, while the proposed model would also end the 'race to the bottom' within the European Union. If the European Union were to be the first mover, self-interest would prompt other countries and regions to follow its lead. The resulting production location neutrality would encourage international businesses to embrace the model and lobby for transition as rapidly as possible. Driven by self-interest and competitive responses, such a move could initiate a transition to the worldwide adoption of destination-based taxation of excess earnings - in other words, harmonization through competition. As the innovator, the European Union would enjoy the greatest economic benefit during the transitional period, when countries' profit tax systems would be evolving towards an equilibrium in which destination-based tax would become the new global standard. The final destination would be a new destination-based company tax paradigm operating both neutrally and non-discriminatorily on the supply side. That would produce a result that would not only be fair, but would also - and primarily - provide a systemic and economically efficient solution for the international problem of BEPS.
Author | : Maarten De Wilde |
Publisher | : |
Total Pages | : 0 |
Release | : 2023 |
Genre | : |
ISBN | : |
Download On the Future of Business Income Taxation in Europe Book in PDF, ePub and Kindle
How should Europe respond to society's calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the CCTB/CCCTB draft directives into a new system of international taxation, i.e. a unitary taxation model for taxing the worldwide economic profits of multinationals, using a destination-based apportionment formula (CCCTB 2.0) to apportion the tax base to countries both within and outside the European Union. Under such a system, it would be up to the EU Member States themselves to determine the rate applying to the tax base apportioned to them. This would take tax out of the equation in the case of marginal financing and investment decisions, while also curtailing its influence on investment location decisions and, at the same time, making 'gaming the system' more difficult. EU Member States would, in turn, regain their autonomy to set their corporate tax rates at the levels they regard as appropriate, while the proposed model would also end the 'race to the bottom' within the European Union. If the European Union were to be the first mover, self-interest would prompt other countries and regions to follow its lead. The resulting production location neutrality would encourage international businesses to embrace the model and lobby for transition as rapidly as possible. Driven by self-interest and competitive responses, such a move could initiate a transition to the worldwide adoption of destination-based taxation of excess earnings - in other words, harmonization through competition. As the innovator, the European Union would enjoy the greatest economic benefit during the transitional period, when countries' profit tax systems would be evolving towards an equilibrium in which destination-based tax would become the new global standard. The final destination would be a new destination-based company tax paradigm operating both neutrally and non-discriminatorily on the supply side. That would produce a result that would not only be fair, but would also - and primarily - provide a systemic and economically efficient solution for the international problem of BEPS.Full-text Paper.
Author | : OECD |
Publisher | : OECD Publishing |
Total Pages | : 82 |
Release | : 1998-05-19 |
Genre | : |
ISBN | : 9264162941 |
Download Harmful Tax Competition An Emerging Global Issue Book in PDF, ePub and Kindle
Tax competition in the form of harmful tax practices can distort trade and investment patterns, erode national tax bases and shift part of the tax burden onto less mobile tax bases. The Report emphasises that governments must intensify their cooperative actions to curb harmful tax practices.
Author | : Ray Palmer Baker |
Publisher | : |
Total Pages | : 360 |
Release | : 1966 |
Genre | : Income tax |
ISBN | : |
Download Taxation of Foreign Income by United States and Other Countries Book in PDF, ePub and Kindle
Author | : Maria Hilling |
Publisher | : |
Total Pages | : 370 |
Release | : 2017 |
Genre | : |
ISBN | : |
Download Free Movement and Tax Treaties in the Internal Market Book in PDF, ePub and Kindle
This book deals with the impact of the EU free movement rules on tax treaties in the internal market. A substantial part of the study consists of identifying the rights and obligations stemming from the free movement rules. As they are not very detailed, the case law is crucial. Therefore, this book includes extensive case law studies, focusing primarily on cases where the 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.
Author | : United States. Internal Revenue Service |
Publisher | : |
Total Pages | : 28 |
Release | : 1990 |
Genre | : Double taxation |
ISBN | : |
Download U.S. Tax Treaties Book in PDF, ePub and Kindle
Author | : Harry Huizinga |
Publisher | : |
Total Pages | : 64 |
Release | : 2003 |
Genre | : Corporations, Foreign |
ISBN | : |
Download Foreign Ownership and Corporate Income Taxation Book in PDF, ePub and Kindle
Recoge : 1. Introduction. - 2. Previous literature. - 3. The data. - 4. The estimation. - 5. Empirical results. - 6. Conclusions.