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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...
Persistent link: https://www.econbiz.de/10010421432
, provisions for future pension payments, provisions for legal obligations, avoidance of double taxation regarding dividend income …
Persistent link: https://www.econbiz.de/10003846095
Ongoing tax reform processes, competitive pressures and the consequences of the financial and sovereign debt crisis have considerably shaped the tax systems of the Member States of the European Union in the last two decades. Our paper combines a qualitative and quantitative analysis of the...
Persistent link: https://www.econbiz.de/10011720019
an MNG: the tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We …
Persistent link: https://www.econbiz.de/10010357931
effects that determine the decision of an MNG: the tax-utilization of losses, the allocation of the tax base, the dividend and …
Persistent link: https://www.econbiz.de/10010422188
The common consolidated corporate tax base has been suggested as a way to curb tax avoidance by allocating profits across borders via a formula. This paper demonstrates that when transfer pricing occurs both for tariff and tax minimization, that moving from separate accounting to formula...
Persistent link: https://www.econbiz.de/10010128410
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 March 16, 2011. In the context of the Europe 2020 Strategy, major objectives of the proposed CCCTB are the...
Persistent link: https://www.econbiz.de/10009553619
Since its conception, some within the European Union have expressed concerns over the ability of multinationals to avoid taxation by undertaking transfer pricing to shift profits towards low tax locations. These concerns have been growing, leading to a renewed call for a common consolidated...
Persistent link: https://www.econbiz.de/10009733757
This paper surveys and evaluates the corporation tax (CT) systems of the Member States of the European Union on the basis of a comprehensive taxonomy of actual and potential regimes, which have as their base either profits, profits and interest, or economic rents. The current regimes give rise...
Persistent link: https://www.econbiz.de/10011436091
The European Commission favours the introduction of a consolidated corporate tax base to overcome the distortions arising from the existing system of separate accounting. The blueprints for consolidation are simulated with the applied general equilibrium model CORTAX. We show that the benefits...
Persistent link: https://www.econbiz.de/10011372975