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The EU Common Consolidated Corporate Tax Base: Critical Analysis

The EU Common Consolidated Corporate Tax Base: Critical Analysis

作者： Dennis Weber; Jan van de Streek
出版商： Kluwer Law International
ISBN: 9789041192332
出版时间 December 2017
规格： Hardback , 272 pages
适应领域： European Union ? 免责申明：
Countri(es) stated herein are used as reference only

List Price: ￥1,184.40

￥1,148.87 Save ￥35.53 (3%)

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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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