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Vol 21 No 10 Oct/Nov 2016

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Corporate Income Taxation in Europe: The Common Consolidated Corporate Tax Base (CCTB) and Third Countries

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Edited by: Michael Lang, Pasquale Pistone, Josef Schuch

ISBN13: 9781782545415
Published: October 2013
Publisher: Edward Elgar Publishing Limited
Country of Publication: UK
Format: Hardback
Price: £101.00



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This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies. The book considers the impact of the CCCTB from the perspective of non-EU-based enterprises that are carrying on business in the EU through the operation of branches or subsidiaries in Member States. It incorporates the perspectives of leading scholars from all over Europe as well as from third countries such as the United States, and provides in-depth analysis of the key aspects which would affect third countries, such as: withholding taxation, taxation of transparent entities, and transfer of assets to third countries. Corporate Income Taxation in Europe will provide essential insights to academics, practitioners and policymakers in the field of taxation. It will also interest those looking ahead to future tax reforms in the EU, or considering how a similar model may be applied elsewhere.

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Subjects:
Taxation
Contents:
Preface
1. Taxation of EU-Resident-Companies Edoardo Traversa and Charles-Albert Helleputte
Taxation of EU Resident Companies under the Current CCCTB Framework: Descriptive and Critical Approach to Selected 'Extraterritorial' Aspects With commentary from Krister Andersson and Katharina Becker
2. Taxation of EU-Non-Resident-Companies Eric C.C.M Kemmeren and Daniel S. Smit
Taxation of EU-Non-Resident-Companies under the CCCTB System: Analysis and Suggestions for Improvement With commentary from Theo Keijzer
3. Resident and Non-Resident Taxpayers Guglielmo Maisto The Meaning of 'Resident Taxpayer' and 'Non-Resident Taxpayer' under the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)
4. Withholding Taxation Joachim Englisch Withholding Taxation With commentary from Dennis Weber and Jan van de Streek
5. Transparent Entities Yariv Brauner CCCTB and Fiscally Transparent Entities - A Third Countries' Perspective With commentary from Jorg Hernler and Christian Kaeser
6. Deductibility of Gifts to Charitable Bodies in Third Countries Roman Seer Deductibility of Gifts to Charitable Bodies in Third Countries With commentary from Mitchell A. Kane
7. Transfer of Assets to Third Countries Daniel Gutmann Transfer of Assets Towards Third Countries
8. Interest Deductibility Pasquale Pistone The Limits to Interest Deductibility: An Ad Hoc Anti-abuse Rule in the Proposal for a CCCTB Directive With commentary from Christoph Spengel
9. CFC Christiana HJI Panayi CFC Rules within the CCCTB With commentary from Walter Hellerstein and Richard Lyal
Index