Corporate Income Taxation In Europe The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries

Preface

1. Taxation of EU-Resident-Companies
Edoardo Traversa and Charles-Albert Helleputte

Taxation of EU Resident Companies under the Current CCCTB Framework: Descriptive and Critical Approach to Selected ‘Extraterritorial’ Aspects
With commentary from Krister Andersson and Katharina Becker

2. Taxation of EU-Non-Resident-Companies
Eric C.C.M Kemmeren and Daniël S. Smit

Taxation of EU-Non-Resident-Companies under the CCCTB System: Analysis and Suggestions for Improvement
With commentary from Theo Keijzer

3. Resident and Non-Resident Taxpayers
Guglielmo Maisto

The Meaning of ‘Resident Taxpayer’ and ‘Non-Resident Taxpayer’ under the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)

4. Withholding Taxation
Joachim Englisch

Withholding Taxation
With commentary from Dennis Weber and Jan van de Streek

5. Transparent Entities
Yariv Brauner

CCCTB and Fiscally Transparent Entities – A Third Countries’ Perspective
With commentary from Jörg Hernler and Christian Kaeser

6. Deductibility of Gifts to Charitable Bodies in Third Countries
Roman Seer

Deductibility of Gifts to Charitable Bodies in Third Countries
With commentary from Mitchell A. Kane

7. Transfer of Assets to Third Countries
Daniel Gutmann

Transfer of Assets Towards Third Countries

8. Interest Deductibility
Pasquale Pistone

The Limits to Interest Deductibility: An Ad Hoc Anti-abuse Rule in the Proposal for a CCCTB Directive
With commentary from Christoph Spengel

9. CFC
Christiana HJI Panayi

CFC Rules within the CCCTB
With commentary from Walter Hellerstein and Richard Lyal

Index