The taxation of dividends is characterized by the fact that the taxable object stems from profits that will usually have already been taxed at the level of the distributing company. If the second layer of taxation at the shareholder level constitutes economic double taxation, to what extent, if...

The draft for a CCCTB Directive in the EU includes the suggestion for an apportionment formula which allocates taxable profits to group member corporations and to the respective Member States. The draft directive delegates the right to define one apportionment factor, the term ‘Employee’ to...

One of the main features of the common consolidated corporate tax base (CCCTB) Draft Directive, the formulary apportionment of the consolidated group income, leads to a significant change in corporate income taxation paradigms. Currently, corporations are taxed on a separate entity basis using...

After intensive and extensive preparation, the European Commission released the long-awaited proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) on 16 March 2011. In the context of the Europe 2020 Strategy, major objectives of the proposed CCCTB are the...

The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting...

In recent years, the European Court of Justice (ECJ) has invalidated many income tax law provisions of EU member states as violating the guarantees of the European constitutional treaties of freedom of movement for goods, services, persons, and capital. These decisions have not, however, been...