Download PDF by Professor Dr. Christoph Spengel (auth.), Christoph Spengel,: Common Corporate Tax Base (CC(C)TB) and Determination of

By Professor Dr. Christoph Spengel (auth.), Christoph Spengel, York Zöllkau (eds.)

ISBN-10: 3642284329

ISBN-13: 9783642284328

ISBN-10: 3642284337

ISBN-13: 9783642284335

The learn carried out via the Centre of eu financial study (ZEW), the college of Mannheim and Ernst & younger contributes to the continuing overview of the idea for a Draft Council Directive on a typical Consolidated company Tax Base (CC(C)TB) published by means of the eu fee on March sixteen, 2011. For the 1st time, information at the selection of taxable source of revenue below the proposed Council Directive are in comparison to triumphing company tax accounting laws in all 27 Member States, Switzerland and the USA. The learn offers proof at the scope of transformations and similarities among nationwide tax accounting laws and the Directive’s remedy in a whole, but concise shape. in line with this accomplished comparability, it is going directly to talk about ultimate open questions and changes wanted if the Directive is to be applied in nationwide tax legislations. Readers looking a foundation for taking an energetic half within the public debate will discover a invaluable resource of knowledge and a primary impact of the way the proposed CC(C)TB could impact company tax burdens within the ecu Union.

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24 25 26 See Sørensen (2004), p. 97. 2 and Fuest (2008), p. 738. See for details Cerioni (2011), pp. 527-529. 3. ) Third Countries: Treatment of Outbound and Inbound Investments The territorial scope of the proposed CCCTB is, in general terms, limited to the boundaries of the EU; however, consideration has also to be given to business activities between Member States and third countries. In this respect, outbound and inbound investment can be distinguished. Regarding outbound investment, the proposed Council Directive principally provides clear guidance on how foreign source income is taxed: Dividends received (Article 11 (c)) and income from permanent establishments (Article 11 (e)) in third countries are generally tax exempt.

And Schön (2004), pp. 426 ff. See Spengel/Malke (2008), p. 88 and Freedman/Macdonald (2008). 20 C. 42 Thus, and since financial accounting converges more and more across Europe, differences between the national tax systems cannot be found in the starting point of determining taxable income, but rather in the number and extent of prescribed deviations between financial and tax accounting. ) in order to determine taxable income. 44 Only in Bulgaria, Cyprus, Estonia, Malta and Portugal, the profits shown in the financial accounts drawn up in accordance with IAS/IFRS form, in practice, the basis on which taxable income is determined.

Finally, it has to be pointed out that corporations in Estonia are subject only to a flat-rate tax on distributed profits including transactions that are considered hidden profit distribution. Many issues surrounding the determination of taxable income – as known in all other considered countries – are, therefore, not applicable to the Estonian tax system. Accordingly, attention is paid to Estonia in the following subchapters only where appropriate. 2. , Article 9 of the proposed Council Directive defines two of the general principles underlying the determination of the tax base: First, the item-byitem principal (Article 9 (2)), which states that all transactions and taxable events shall be measured individually, and, second, the consistency requirement (Article 9 (3)), stating that the determination of the tax base shall be carried out in a consistent manner.

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Common Corporate Tax Base (CC(C)TB) and Determination of Taxable Income: An International Comparison by Professor Dr. Christoph Spengel (auth.), Christoph Spengel, York Zöllkau (eds.)


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