Integration Approaches to Group Taxation in European Internal Market

Integration Approaches to Group Taxation in European Internal Market

The creation of a group taxation framework to subject affiliated entities resident in more than one EC Member State to a single set of rules is an experiment without precedent. Group taxation normally deals with tax liability in the context of a single jurisdiction. There is no system of group taxation worldwide which embraces more than one fiscal jurisdiction under a single regulatory umbrella.

This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse.

Among the topics covered...

• The relevant jurisprudential and legislative framework of the European Internal Market;
• A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers;
• The policies for corporate taxation in integrated markets;
• Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability;
• Tests for entitlement to group membership;
• Tax base integration; - Territorial delineation of the group; and
• Formulary apportionment.

In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.