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Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law

Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law

Author: Savvas Kostikidis
Publisher: Kluwer Law International
ISBN: 9789403538587
Published In: October 2024
Format: Hardback
Jurisdiction: Netherlands ? Disclaimer:
Countri(es) stated herein are used as reference only

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Description
Contents

Details

Residence and Economic Substance of Subsidiary Corporations in International and European Tax Law is a trailblazing book scrutinizing the content of the substance requirement in double tax convention residence rules, transfer pricing rules, anti-abuse rules in tax treaties, and controlled foreign corporation rules in the context of international and EU tax law, unraveling the complex relationship between the substance requirements in these four sets of legal rules.

What’s in this book:

Following a descriptive-analytic method, for each substance requirement of the four sets of legal rules, the discussion deals with the content of economic substance in complex scenarios, for example:

holding companies
special purpose vehicles
loss-making subsidiaries
subsidiaries with management in more than one state
subsidiaries managed by the parent company
outsourcing, and
subsidiaries ‘borrowing’ the substance of other group companies

The author introduces a new method of assessment of substance requirements, offering practical solutions for their uniform application in international and European tax law.

How this will help you:

This peerless book thoroughly examines how substance requirements work and how they are interrelated among different sets of tax rules. Taxation practitioners and corporate counsel in Europe and globally will highly appreciate it.

List of Abbreviations

List of Figures

List of Tables

Acknowledgements

Introduction. Combating Tax Arbitrage via Subsidiary Corporations with Substance-Oriented Rules

CHAPTER 1. The Substance Requirement for the Purposes of Treaty Corporate Residence

CHAPTER 2. The Substance Requirement for the Purposes of Transfer Pricing Rules

CHAPTER 3. The Substance Requirement for the Purposes of DTC Treaty Shopping Rules

CHAPTER 4. The Substance Requirement in the EU Tax Law Context

Conclusions

Bibliography