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Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income
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 in a Global Digital Economy
Time to discuss anti-BEPS measures around digitalization In the course of the BEPS Report on Action 1, it was concluded that there was no instantaneous need for specific rules to address base erosion and profit shifting (BEPS) made possible by the digitalization of enterprises and new digital businesses. At the same time, it was acknowledged that general measures may not suffice with the assessment of results to begin in 2020. While awaiting possible fundamental reforms of the tax framework, it is time to discuss anti-BEPS measures bearing in mind the peculiar features of the digital economy such as increased mobility, no need for physical presence, and dematerialization. The Book focuses on five key areas of interest:International Tax PolicyTax Treaty LawTransfer PricingIndirect Taxation IssuesEU Law “Taxation in a Global Digital Economy” analyses the issues and addresses the five key areas of interest from various viewpoints.
Common Corporate Tax Base in the EU
The European Commission envisages putting forward a proposal for a tax reform that would allow improving the efficiency and simplicity of the corporate income tax systems. This report assesses the impact of a Common Corporate Tax Base (CCTB) on the size of the corporate tax bases of EU companies. The results of the report shall help to evaluate the economic consequences of the introduction of a harmonised set of tax accounting rules. The estimates are based on the European Tax Analyzer with data from the year 2006 and apply options specified by the Commission’s Steering Group.
Multilateral Cooperation in Tax Law
An in-depth analysis of various aspects of multilateral cooperation in tax law Tax evasion and aggressive tax planning causing base erosion and profit shifting (BEPS) has been a widely discussed topic among academics and tax policy makers over the past decades. Increasing globalization and digitalization have contributed to the intensification of this issue in recent years. At the same time, states continue to largely insist on their sovereignty in the area of tax law. However, due to their cross-border nature, issues related to BEPS are shared problems among the states and can typically not be solved by a single nation. Therefore, multilateral cooperation represents an option to build a bri...
Company Taxation in the Asia-Pacific Region, India, and Russia
The Asian-Pacific countries as well as India and Russia offer multinational companies all the benefits of booming economies in a world of recession. However, the investor must be aware of the tax regime under which he will operate. This survey presents the rates, definitions of taxable income and the incentives available in a complete, yet concise form. It goes on to review tax minimisation strategies and concludes with a comparison of the overall tax burdens for investors in each country derived from the Devereux/Griffith formulae – a methodology well known within the EU, but applied to this region for the first time.
Effective Tax Burden in Europe
This book summarises the results of a study on behalf of the European Commission. It presents estimates of effective average tax rates (EATR) in five EU Member States plus the USA. The main aim is to compare EATR on domestic investments by companies. A secondary aim is to work out the impact of the different tax drivers on the tax burden. The comparison is made in six stages: - Comparison of the EATR for a base case - Effects of alternative assumptions on the economic data - Comparative effects of the German tax reform from 1 January 2001 - Consequences of the most important tax reforms since 1995 - Effects of hypothetical tax reforms - Comparison with results obtained from other studies.
Transfer Pricing and Value Creation
Value Creation and its effects on Transfer Pricing and tax law Emerging from the OECD/G20 BEPS Project, a new, somewhat fuzzy notion of Value Creation came to permeate not only Transfer Pricing language but also wider allocation rules and anti-abuse provisions in international tax law. The notion of ‘Value Creation’ reframes the interpretation and application of the Arm’s Length Principle (ALP) that is embedded in Articles 7 and 9 of the OECD Model Convention. This new Value Creation notion and approach assist in understanding key enterprise functions while different industry sectors manifest these concepts in various ways. Situating such notions and this approach within the law of tax...
Measuring the Effective Levels of Company Taxation in the New Member States
Recoge: 1.Introduction - 2.Methodology and theorical framework - 3.Corporate taxation in the new member states - 4.Effective tax burdens on domestic investments in the new member states - 5.Effective tax burdens on german outbound investments to the new member states.
International Company Taxation and Tax Planning
This book provides a description and analysis of tax systems worldwide. It offers practical guidance on international planning approaches from a team of both tax practitioners and academics. In addition to references to country-specific tax legislation - including laws and rules in all EU Member States plus the United States, as well as special provisions in Australia, Japan, and elsewhere - the book discusses important ECJ decisions and various other case studies.
Home State Taxation
Examines the proposal for home state taxation as a way to eliminate the principal barriers to the completion of the internal market in the corporate tax field. Includes an assessment by the IBFD of the compatibility of home state taxation with double taxation agreements, based on the OECD Model Convention.
