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The EU Common Consolidated Corporate Tax Base: Critical Analysis

The EU Common Consolidated Corporate Tax Base: Critical Analysis

  • Author:
  • Publisher: Kluwer Law International
  • ISBN: 9789041192332
  • Published In: December 2017
  • Format: Hardback , 272 pages
  • Jurisdiction: European Union ? Disclaimer:
    Countri(es) stated herein are used as reference only

List Price: HKD 1,260.00

HKD 1,184.40 Save HKD 75.60 (6%)

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  • Description 
  • Contents 
  • Details

    The EU Common Consolidated Corporate Tax Base: Critical Analysis serves as a guide to the major development in EU tax law, the Common Consolidated Corporate Tax Base (CCCTB) proposal. In October 2016, the European Commission relaunched its plan to harmonize national income tax systems via the CCCTB by introducing a single set of rules to calculate companies’ taxable profits in the EU. This timely book offers an early analysis of this important proposal and its implications, covering issues such as the project’s scope and main elements, international considerations, the relationship with OECD’s base erosion and profit shifting (BEPS) initiative, consolidation, and anti-abuse rules.

    What’s in this book:

    With carefully selected papers first presented at a January 2017 conference hosted by the Amsterdam Centre for Tax Law, this volume focuses on such topics and issues as the following:

    • ways in which the proposed CCCTB is designed to preserve the competence of Member States to set their tax rates;
    • reduction of the administrative burden for multinational companies;
    • incentives for research and development;
    • automatic cross-border relief within the EU;
    • detailed analysis of the proposal’s formula apportionment regime;
    • proposed new controlled foreign (CFC) rules; and
    • interest limitation rule.

    How this will help you:

    Because of the commitment of many Member States to keep their corporate income tax systems competitive on a stand-alone basis, the proposed CCCTB is enormously controversial and is perhaps the most ambitious reform of EU tax law ever attempted. As a detailed assessment of the reform, this book provides authoritative insights into problems likely to arise and discusses the prospect of how to implement the proposal. Thus, this book proves to be of immeasurable value to taxation policymakers, practitioners, and academics to apply this reform confidently across international boundaries.

  • Editors

    Contributors

    Preface

    CHAPTER 1
    Some Introductory Remarks on the Relaunched CCTB/CCCTB Proposals from a Policy Perspective
    Jan van de Streek

    CHAPTER 2
    Principles and Characteristics of CCTB after the Relaunch
    Ronald Russo

    CHAPTER 3
    Depreciation Rules and Roll-Over Relief under the Proposed CCTB Directive
    Hein Vermeulen

    CHAPTER 4
    Allowance for Growth and Investment
    Stefano Grilli

    CHAPTER 5
    The R&D Tax Incentives
    Paolo Arginelli

    CHAPTER 6
    The Participation Exemption
    Marjaana Helminen

    CHAPTER 7
    Cross-Border Loss Relief under the Proposed CCTB Directive
    Bruno da Silva

    CHAPTER 8
    The Arm’s Length Standard: A Blind Spot in the CC(C)TB Proposals
    Daniel S. Smit

    CHAPTER 9
    Exit Tax
    Rita Szudoczky

    CHAPTER 10
    Tax Avoidance and the Return of CC(C)TB
    Frans Vanistendael

    CHAPTER 11
    Interest Limitation Rule
    Ruben Martini

    CHAPTER 12
    The Switch-Over Clause
    Daniel Gutmann

    CHAPTER 13
    The Controlled Foreign Company Regime
    Werner Haslehner

    CHAPTER 14
    The GAAR
    Markus Seiler

    CHAPTER 15
    Consolidation Within the CCCTB
    Fabian Munsterman

    CHAPTER 16
    Tax Competition Within the European Union Revisited: Is the Relaunched CCCTB a Solution?
    Maarten F. de Wilde

    CHAPTER 17
    Procedural and Administrative Aspects of the CCCTB
    Sjoerd Douma

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