Integration Approaches to Group Taxation in the European Internal Market

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Release : 2008-10-13
Genre : Law
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Book Rating : 338/5 ( reviews)

Integration Approaches to Group Taxation in the European Internal Market - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Integration Approaches to Group Taxation in the European Internal Market write by Ioanna Mitroyanni. This book was released on 2008-10-13. Integration Approaches to Group Taxation in the European Internal Market available in PDF, EPUB and Kindle. 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.

Traditional and Alternative Routes to European Tax Integration

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Release : 2010
Genre : Business tax
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Book Rating : 839/5 ( reviews)

Traditional and Alternative Routes to European Tax Integration - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook Traditional and Alternative Routes to European Tax Integration write by Dennis Weber. This book was released on 2010. Traditional and Alternative Routes to European Tax Integration available in PDF, EPUB and Kindle. Tax integration within the European Union can take place in many ways. In this book, various instruments which the Member States and the European Union have available to attain tax integration are discussed and their mutual relationship is studied. The book includes a general report drafted by the editor and is divided into seven parts focusing on (i) Sources of EU law for integration in direct and indirect taxation, (ii) Soft law: Solution or disillusion? Limits?, (iii) Infringement procedures: Another way to move things further?, (iv) Comitology, (v) Relationship between primary and secondary EU law, (vi) VAT Directive tested against primary law, and (vii) Direct tax directives tested against primary law. The book is the outcome of the fourth annual conference of the GREIT (Group for Research on European and International Taxation).

The Impact of Tax Treaties and EU Law on Group Taxation Regimes

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Release : 2016-07-11
Genre : Law
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Book Rating : 091/5 ( reviews)

The Impact of Tax Treaties and EU Law on Group Taxation Regimes - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook The Impact of Tax Treaties and EU Law on Group Taxation Regimes write by Bruno da Silva. This book was released on 2016-07-11. The Impact of Tax Treaties and EU Law on Group Taxation Regimes available in PDF, EPUB and Kindle. Should the income of a corporate group be taxed differently solely because the traditional structure of the income tax system considers each company individually? Taxation affects business decisions, including location, the form in which business is carried out, and the efficient allocation of company resources. Disparities – differences arising from the interaction of different tax systems – and obstacles – distortions created by domestic legislation arising from differences between domestic and cross-border situations – both become more acute when a business chooses to set up or acquire other companies, thus forming a group, usually operating in multiple jurisdictions. Responding to such ever more common developments, this book is the first in-depth analysis of how tax treaties and EU law influence group taxation regimes. Among the issues and topics covered are the following: – analysis of the different tax group regimes adopted by different countries; – advantages and disadvantages of a variety of models; – application of the non-discrimination provision of Article 24 of the OECD Model Tax Convention to group taxation regimes; – application of the fundamental freedoms of the TFEU to group taxation regimes following the three-step approach adopted by the EU Court of Justice; – uncertainty raised by the landmark Marks & Spencer case, its interpretation and consequences to other group taxations regimes; – interrelations between tax treaties and EU Law in the context of tax groups; and – per-element approach. The analysis considers concrete examples as well as relevant case law. With its analysis of the standards required by the two sets of norms (tax treaties and EU law) and their interaction, particularly in terms of non-discrimination, this book sheds clear light on ways to overcome the disparities and obstacles inherent in group taxation regimes. As a thorough survey of the extent to which the interpretation of tax treaties and EU law affect group taxation regimes, this book has no peers. All taxation professionals, whether working in EU Member States or in EU trading partners, will appreciate its invaluable insights and guidance.

European Tax Integration

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Release : 2018
Genre : Taxation
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Book Rating : 745/5 ( reviews)

European Tax Integration - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook European Tax Integration write by Pasquale Pistone. This book was released on 2018. European Tax Integration available in PDF, EPUB and Kindle. This book focuses on the status quo of European tax integration, combining law, policy and politics. Good policy should identify and address problems when they arise, achieving suitable solutions that law implements. Within the European Union, this relation is malfunctioning or entirely missing in direct tax matters. Positive tax integration in the European Union has mostly failed to transform supranational policy goals into actual measures of harmonization and coordination, except for the recent reaction to tax avoidance. The topical studies contained in this book hold that without a proper action that removes cross-border tax obstacles, positive tax integration shifts away from its original goals. Furthermore, such a scenario leaves the bulk of European tax integration in the hands of the limits established by negative tax integration, with little room for developing a structured policy in the interest of the European Union. This peer-reviewed publication aims to stimulate debate among scholars, decision-makers, practitioners, politicians and interpreters of European international tax law, with a view to bringing European tax integration back on the right track.

The Taxation of Corporate Groups Under Consolidation

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Release : 2013
Genre : Business & Economics
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Book Rating : 497/5 ( reviews)

The Taxation of Corporate Groups Under Consolidation - read free eBook in online reader or directly download on the web page. Select files or add your book in reader. Download and read online ebook The Taxation of Corporate Groups Under Consolidation write by Antony Ting. This book was released on 2013. The Taxation of Corporate Groups Under Consolidation available in PDF, EPUB and Kindle. Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries.