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Corporate Income Taxation In Europe

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

Author: Michael Lang; Pasquale Pistone; Josef Schuch; Claus Staringer; Alfred Storck
Publisher: Edward Elgar Publishing
ISBN: 9781782545415
Published In: November 2013
Format: Hardback , 384 pages
Jurisdiction: European Union ? Disclaimer:
Countri(es) stated herein are used as reference only

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Contents
Author

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This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies.

The book considers the impact of the CCCTB from the perspective of non-EU-based enterprises that are carrying on business in the EU through the operation of branches or subsidiaries in member states. It incorporates the perspectives of leading scholars from all over Europe as well as from third countries such as the United States, and provides in-depth analysis of the key aspects which would affect third countries, such as: withholding taxation, taxation of transparent entities, and transfer of assets to third countries.

Corporate Income Taxation in Europe will provide essential insights to academics, practitioners and policymakers in the field of taxation. It will also interest those looking ahead to future tax reforms in the EU, or considering how a similar model may be applied elsewhere.

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

Edited by Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck, Institute for Austrian and International Tax Law, WU, Austria