scholarly journals Cross-Border Group-Taxation and Loss-Offset in the EU - An Analysis for CCCTB (Common Consolidated Corporate Tax Base) and Etas (European Tax Allocation System)

2009 ◽  
Author(s):  
Claudia Dahle ◽  
Michaela Üffing
Keyword(s):  
Corporate Tax ◽  
Tax Base ◽  
Allocation System ◽  
Cross Border ◽  
Group Taxation ◽  
Loss Offset ◽  
The Eu

Besteuerungsprinzipien und effektive Unternehmenssteuerbelastungen in der Europäischen Union: Regelt sich die EU-weite Steuerharmonisierung von selbst?

2011 ◽  
Vol 12 (1) ◽  
pp. 47-71 ◽  
Author(s):  
Christina Elschner ◽  
Jost H. Heckemeyer ◽  
Christoph Spengel
Keyword(s):  
European Union ◽  
Investment Decisions ◽  
Tax Rates ◽  
Eu Law ◽  
The European Union ◽  
Corporate Tax ◽  
Cross Border ◽  
Tax Regimes ◽  
Country Specific ◽  
The Eu

AbstractEU law demands that the allocation of factors and goods within the European Union shall not be distorted by taxes. Efforts to formally harmonize corporate tax regimes in Europe have, however, stalled in recent years. What is more, the source principle has prevailed over residence based taxation which is seen to be more in line with EU law. Tax induced distortions of cross-border investment decisions are supposed to be the consequence. Based on country-specific effective average tax rates from 1998 to 2009, this article shows that there is, however, non-coordinated convergence of tax burdens within the EU. Thus, distortions of cross-border investment decisions are limited and decreasing even without formal harmonization.

scholarly journals The international Challenges and Finnish Corporate Taxation

2014 ◽  
Vol 2014 (2) ◽  
pp. 132-148
Author(s):  
Juha Lindgren
Keyword(s):  
Corporate Taxation ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Rate ◽  
Cross Border ◽  
Exchange Of Information ◽  
The Cross ◽  
National Tax

Abstract One of the main trends in Finnish corporate taxation during the last ten years has been the lowering of the corporate tax rate. The decision to lower the corporate tax rate to 20% from the beginning of 2014 also changed the approach in reforming the corporate taxation as it was decided to stay on the grounds of a broad tax base and not to make loopholes in it with targeted exceptions. The Finnish corporate taxation contains also some provisions that act as incentives for investment and the establishment of companies. However, the focus has been lately on the rules with purpose to protect the national tax base. Therefore, article handles both the specific anti avoidance rules and the application of the general anti avoidance rule on the cross-border transactions. Some particular challenges and the exchange of information are also taken into account before the conclusion with some ideas and aspects on future reforms.

scholarly journals Consolidation under CCCTB system

2008 ◽  
Vol 56 (6) ◽  
pp. 181-188
Author(s):  
Danuše Nerudová
Keyword(s):  
European Commission ◽  
Pilot Project ◽  
Corporate Tax ◽  
Tax Base ◽  
Member States ◽  
Corporate Income Taxation ◽  
Eu Member States ◽  
State Taxation ◽  
Taxation System ◽  
The Eu

In 2007, when the pilot project of Home State Taxation System should started, but none of the EU Member States applied for, the European Commission has turned its attention to different project in the area of corporate income taxation. The paper presents the problems of consolidation under the system of Common Consolidated Corporate Tax Base, which is at present the aim of the European Commission in the area of corporate tax harmonization. Firstly, the paper presents the results of comparative analysis, which have been done throughout the EU Member States. The research was aimed at the area of group taxation schemes availability. Secondly, the paper presents the draft of CCCTB directive in the field of creation of the group for taxation purposes, the rules for access and exit from the group and the rules for calculation of thresholds for voting rights. The different possibilities of group creation are presented on the schemes. The paper also discuss the rules, suggested by the draft directive, which could create legal uncertainty for the companies and could cause the situation in which the companies would not know whether they can consolidate their accounting results or not, or whether they are the member of the group or not. The paper suggests the possible solutions in that area. At the end, there are also mentioned and discussed the methods, which could be used for consolidation under CCCTB system in the EU.

scholarly journals CFC rules in the context of the proposed CCCTB directive

2011 ◽  
Vol 59 (7) ◽  
pp. 363-370
Author(s):  
Veronika Sobotková
Keyword(s):  
Tax Avoidance ◽  
The European Union ◽  
Corporate Tax ◽  
Tax Base ◽  
Tax Preference ◽  
Cross Border ◽  
Council Directive ◽  
Pros And Cons ◽  
Low Costs ◽  
Cfc Rules

In the proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) there have been introduced a specific anti-abuse provisions, CFC rules. These rules are aimed at tax evasions and tax avoidance. The basic principle is the protection of the tax base against erosion through practices of artificial income shifting. Generally, CFC rules prevent tax avoidance in a state of a shareholder by denying the deferred taxation of profits generated by its controlled company, which is a resident in a tax preference jurisdiction. Even thought the CCCTB directive would be aided easier and low-costs cross-border business as well as it would be restricted the harmful tax competition there are questions whether it is advisable to introduce these rules into such system of the CCCTB, whether these rules are compatible with the CCCTB and whether it is regulated properly. So, the focus of this paper rests on the interaction of the proposed CCCTB directive with existing CFC rules in the European Union. The paper deals with pros and cons, economic and legal perspectives these rules in the context of the proposed CCCTB directive.

scholarly journals Possibilities of harmonization of direct taxes in the EU

2017 ◽  
Vol 14 (2) ◽  
pp. 191-199 ◽  
Author(s):  
Adela Feranecová ◽  
Eva Manová ◽  
Marek Meheš ◽  
Jana Simonidesová ◽  
Slavomíra Stašková ◽  
...  
Keyword(s):  
Income Tax ◽  
Slovak Republic ◽  
Complex Problem ◽  
Corporate Income Tax ◽  
Corporate Tax ◽  
Tax Base ◽  
Member States ◽  
Eu Member States ◽  
Tax Harmonization ◽  
The Eu

Currently, indirect taxes in the EU are highly harmonized, however, harmonization of direct taxes is still a very complex problem. Many EU member states refuse to give up their tax sovereignty, which would become considerably limited because of the har¬monization of direct taxes. Today, attention is paid to the harmonization of the tax base of corporate income tax, while a number of ways are under consideration. The European Council has issued a draft of Directive for a common consolidated tax base of corporate income tax in 2011 and updated in 2012. This draft must be approved by all member states, but some of them, however, have expressed on the draft in negative way. Because of the severity of this problems, the authors decided to focus on this topic within this article, which deals with the calculation of the tax base by the laws of the Slovak Republic and by Common Consolidated Corporate Tax Base (CCCTB); and evaluate whether the tax harmonization of direct taxes would be advantageous for the particular business.

Common Corporate Tax Base in the EU

2012 ◽  
Author(s):  
Christoph Spengel ◽  
Andreas Oestreicher
Keyword(s):  
Corporate Tax ◽  
Tax Base ◽  
The Eu

scholarly journals The Peripatetic Nature of EU Corporate Tax Law

2019 ◽  
Vol 24 ◽  
pp. 1-60
Author(s):  
Christiana HJI Panayi
Keyword(s):  
Transfer Pricing ◽  
Tax Law ◽  
Tax Administration ◽  
Tax Rates ◽  
Corporate Tax ◽  
Tax Base ◽  
Potential Impact ◽  
Set Up ◽  
The Eu

This article examines some aspects of the European Union’s corporate tax set-up which correspond to aspects of a country’s corporate tax regime. The overarching question is whether there is such a thing as EU corporate tax law. This article seeks to address this in the context of the following issues: the existence of a uniform tax base and tax rates; the existence of anti-abuse rules and a transfer pricing regime; and, finally, the existence of a common tax administration and its powers. The article questions whether the peripatetic development of EU corporate tax law is suitable for the EU or whether it undermines its long-term objectives. The potential impact of Brexit in the development of EU corporate tax law is also addressed.

Sign in / Sign up

Export Citation Format

Share Document