Integration Approaches to Group Taxation in the European Internal Market
- ISBN-10
- 9041145338
- ISBN-13
- 9789041145338
- Category
- Law
- Pages
- 288
- Language
- English
- Published
- 2008-10-13
- Publisher
- Kluwer Law International B.V.
- Author
- Ioanna Mitroyanni
Description
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.
Get the book
Similar books
-
Global Trends in VAT/GST and Direct Taxation: Schriftenreihe IStR Band 93
By Sebastian Pfeiffer, Marlies Ursprung-SteindlDue to the OECD’s BEPS project, national tax systems are being significantly modified. This book aims at identifying and discussing the current global trends in both VAT/GST and direct taxes.
-
The Impact of Tax Treaties and EU Law on Group Taxation Regimes
By Bruno da Silva43484 bis, case X Holding BV v. Staatssecretaris van Financiën, para. 4.5. See Joachim Englisch, 'X Holding: Looking beyond Loss Relief Issues', in D. Weber & B. da Silva (eds) From Marks & Spencer to X Holding: The Future ...
-
EU Freedoms, Non-EU Countries and Company Taxation
By D.S. SmitEuropean Taxation 2 (2005): 64–71. Sinclair, I. The Vienna Convention on the Law of Treaties, 2nd ed. Manchester: University Press, 1984. Smit, D.S. & B.J. Kiekebeld. 'EC Free Movement of Capital, Corporate Income Taxation and Third ...
-
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future
By Sjaak JansenThis timely resource covers a variety of critical issues, including the current and possible future effects of the internal market on the fiscal sovereignty of Member States; the limits that European law imposes on Member States’ policy ...
-
The Taxation of Corporate Groups Under Consolidation: An International Comparison
By Antony Ting4th Consolidation Symposium organised by Taxation Institute of Australia, Sydney, 1 May 2009) Marino, Giuseppe and ... Integration Approaches to Group Taxation in the European Internal Market, EUCOTAX Series on European Taxation (2008, ...
-
Transfer Pricing Aspects of Intra-Group Financing
By Raffaele Petruzzi(21) Ioanna Mitroyanni, Integration Approaches to Group Taxation in the European Internal Market, 2008 (ISBN 978-90-411-2779-2). (22) Rolf Eicke, Tax Planning with Holding Companies. Repatriation of US Profits from Europe:Concepts, ...
-
Special Tax Zones and EU Law: Theory, Implementations, and Future Challenges
By Claudio Cipollini(21) Ioanna Mitroyanni, Integration Approaches to Group Taxation in the European Internal Market, 2008 (ISBN 978-90-411-2779-2). (22) Rolf Eicke, Tax Planning with Holding Companies. Repatriation of US Profits from Europe:Concepts, ...
-
Corporate Tax Base in the Light of the IAS/IFRS and EU Directive 2013/34: A Comparative Approach
By Mario GrandinettiIoanna Mitroyanni, Integration Approaches to Group Taxation in the European Internal Market, 2008 (ISBN 97890-411-2779-2). Rolf Eicke, Tax Planning with Holding Companies. Repatriation of US Profits from Europe:Concepts, Strategies, ...
-
Double (Non-)Taxation and EU Law
By Christoph MarchgraberSee Footnote 59 to the SCM Agreement. See, for example, R. Luja, Assessment and Recovery of Tax Incentives and the WTO (Intersentia, 2003), at pp. 156-166; C. Micheau, State Aid, Subsidy and Tax Incentives under EU and WTO Law (Kluwer, ...
-
Cooperative Compliance: A Multi-stakeholder and Sustainable Approach to Taxation
By Jeffrey Owens, Jonathan Leigh Pemberton(21) Ioanna Mitroyanni, Integration Approaches to Group Taxation in the European Internal Market, 2008 (ISBN 978-90-411-2779-2). (22) Rolf Eicke, Tax Planning with Holding Companies. Repatriation of US Profits from Europe: Concepts, ...