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Corporate Taxation, Group Debt Funding and Base Erosion: New Perspectives on the EU Anti-Tax Avoidance Directive

Corporate Taxation, Group Debt Funding and Base Erosion: New Perspectives on the EU Anti-Tax Avoidance Directive

Author: Gianluigi Bizioli; Mario Grandinetti; Leopoldo Parada; Giuseppe Vanz; Alessandro Vicini Ronchetti
Publisher: Kluwer Law International
ISBN: 9789403511702
Published In: February 2020
Format: Hardback
Jurisdiction: European Union ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details

About this book:
Corporate Taxation, Group Debt Funding and Base Erosion is the first in-depth analysis of the features and implications of the directive, and it provides insightful and practical discussions by experts from around Europe on the crucial interactions of the Anti-Tax Avoidance Directive (ATAD) with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. The European Union’s (EU’s) ATAD, implemented in January 2019, confronts Member States with complex challenges, particularly through the introduction of specific permanent solutions such as the interest limitation rule. This book pays special attention to the complexities that the introduction of an interest limitation rule may create within the European financial sector.

What’s in this book:
The book is divided into three parts that ensure a proper understanding of the high level of technicalities involving the new ATAD interest limitation rule, as well as the main domestic challenges that Member States are facing with the implementation of this rule. Specific issues and topics covered include the following:

relation with the OECD’s Base Erosion and Profit Sharing project and the EU’s Common Corporate Tax Base initiative;
technical subjects relating to corporate taxation and debt funding;
problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies;
exclusion clauses for interest expenses; and
interplay between interest limitation rules and anti-hybrid rules.

How this will help you:
This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States. A comparative analysis of implementation issues in four leading Member States—Germany, Italy, Spain and the Netherlands—as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated with the implementation of ATAD.

Editors

Contributors

PART I
The Interest Limitation Rule in the ATAD: Targeting Base Erosion

CHAPTER 1
Group Debt Funding and Base Erosion: An Introduction
Peter Essers

CHAPTER 2
The Preference of Debt over Equity for Tax Purposes
Jakob Bundgaard & Michael Tell

CHAPTER 3
The Interest Limitation Rule in the ATAD
Mario Grandinetti

CHAPTER 4
ATAD Interest Expenses Exclusion Clauses
Alessandro Vicini Ronchetti

CHAPTER 5
Interest Limitation Rule and EU Law
Gianluigi Bizioli

PART II
The Interest Limitation Rule in the ATAD: Issues of Implementation

CHAPTER 6
Germany
Daniel Reich

CHAPTER 7
Italy
Giuseppe Vanz

CHAPTER 8
Spain
Andrés Báez Moreno & Aitor Navarro Ibarrola