By Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)
Preface This booklet includes the lawsuits of the overseas Tax convention at the c- th th mon consolidated company tax base (CCCTB) that was once held in Berlin on 15 – sixteen may possibly 2007. The convention used to be together organised by means of the German Federal Ministry of Finance, the Centre for ecu fiscal examine (ZEW), Mannheim, and the Max Planck Institute (MPI) for highbrow estate, pageant and Tax legislations, Munich. greater than 250 members from everywhere Europe and different areas, students, politicians, enterprise humans and tax directors, mentioned the european- pean Commission’s idea to set up a CCCTB. 3 panels of tax specialists evaluated the typical tax base with admire to structural parts, consolidation, allocation, foreign facets and management. The convention made transparent that the CCCTB has the capability to beat the most interesting difficulties of company source of revenue taxation in the universal marketplace. universal tax accounting principles considerably lessen compliance and administrative expenses. Consolidation of a group’s earnings and losses results cro- border loss repayment which eliminates a big tax hindrance for eu cro- border funding. whilst, tax making plans with admire to financing and move pricing is driven again in the ecu Union. furthermore, so far as the CCCTB applies, member states may be able to eliminate tax provisions which are detailed at move border tax evasion and that would be challenged by means of the jurisdiction of the ecu- pean courtroom of Justice.
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Extra resources for A Common Consolidated Corporate Tax Base for Europe — Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa
E. the tax drivers) should be identified. 18 The most important studies by the OECD19 and the European Commission20 17 18 19 20 See King/Fullerton, The Taxation of Income from Capital, Chicago 1984. See Devereux/Griffith, The Taxation of Discrete Investment Choices – Revision 2, IFS Working Paper Series No, W98/16, London 1999. See OECD, Taxing Profits on a Global Economy, Paris 1991. See European Commission, Company Taxation in the Internal Market, 2001. 17 A. Concept and Necessity of a Common Tax Base – an academic introduction apply this methodology.
Moreover, a continued existence of potential conflicts against the fundamental freedoms remains. One can therefore conclude that without further tax coordination member states presumably are not able to reform their tax systems so that they respect the fundamental freedoms of the EC Treaty for cross-border activities and do not destroy the coherence of domestic company taxation at the same time. 4 Is Harmonisation of Nominal Tax Rates a Way Out? The causes of the variations between the effective average company tax burdens (EATR) among the EU member states are complex.
If this were true, EATR on domestic investment should be identical either to the EATR on outbound investment (residence principle) or the EATR on inbound investment (source principle). e. debt financing, retained earnings and new equity). Multinational investors, however, can choose the source of finance of the subsidiary; if one particular source of finance is tax disadvantaged, then it would not be used. Therefore, rather than take an average of the sources of finance, the results presented in the fourth and the fifth bar simply take the most tax efficient means of financing the subsidiary.
A Common Consolidated Corporate Tax Base for Europe — Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa by Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)