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Vol 22 No 11 Nov/Dec 2017

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The Law of Contract Damages

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CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)

Edited by: Dennis Weber

ISBN13: 9789041138729
Published: May 2012
Publisher: Kluwer Law International
Country of Publication: Netherlands
Format: Hardback
Price: £112.00



Low stock.

The European Commission’s proposed Common Consolidated Corporate Tax Base (CCCTB) is the most ambitious project in the history of direct taxation within the EU. While retaining the right of Member States to set their own corporate tax rate, the proposed system allows for a ‘one-stopshop’ for filing tax returns and consolidating prof its and losses across the EU. In this book – the first to offer guidance to practitioners whose work will be affected by these new developments – 19 prominent representatives of the business community, tax consultancy, academic taxation scholarship and tax administration discuss the proposed system’s rationale, structure and uncertainties, ranging from very technical aspects, to the wording of the proposal, to political considerations. These topics include the following: ;

  • eligibility;
  • formation of a group;
  • the concept of ‘permanent establishment’;
  • foreign tax credits;
  • ‘dual resident’ companies;
  • consequences of entering and leaving;
  • depreciation of fixed assets;
  • repackaged asset transfers;
  • appeals procedure;
  • disagreements among Member States;
  • subsidiarity and the ‘yellow card procedure’;
  • international aspects and tax treaties;
  • sharing mechanism and transfer pricing; and
  • anti-abuse rules.
The discussion raises numerous issues likely to lead to future amendments, and for this reason, along with its practical value in developing an understanding of the proposed system’s specif ic effects, the book will be welcomed by tax consultants and lawyers worldwide, corporate tax advisers, European tax authorities and tax researchers and academics.

Subjects:
Taxation
Contents:
List of Contributors.
Preface.
Chapter 1 Consolidation in the CCCTB Proposal 1 Thies Sanders.
Chapter 2 Relevant Aspects When Entering the System/CCCTB Group Paul H.M. Simonis.
Chapter 3 Business Reorganisations within the Group Bertil Wiman.
Chapter 4 Leaving a Group Jan van de Streek.
Chapter 5 CCCTB: General Principles and Characteristics Ronald Russo.
Chapter 6 Depreciation Rules under the Proposed CCCTB Directive 79 Hein Vermeulen .
Chapter 7 Is the CCCTB Proposal in line with the Principle of Subsidiarity?: Negative Opinions Submitted by National Parliaments in the ‘Yellow Card Procedure’ Rita Szudoczky.
Chapter 8 The One-Stop-Shop Approach: A Discussion of the Administrative and Procedural Aspects of the CCCTB Draft Directive J.A.R. van Eijsden.
Chapter 9 Appeals Daniel Gutmann.
Chapter 10 The Common Consolidated Corporate Tax Base and the Future of Taxation Theo Keijzer.
Chapter 11Withholding Taxes and Relief for Double Taxation Matthijs Vogel.
Chapter 12 Common Consolidated Corporate Tax Base: The Sharing Mechanism, Some General Considerations Antonio Russo.
Chapter 13 Tax Planning under the CCCTB’s Formulary Apportionment Provisions: The Good, the Bad and the Ugly Walter Hellerstein.
Chapter 14 CCCTB and Formulary Apportionment: The European Commission Finds the Right Formula Joann Martens Weiner.
Chapter 15 The CCCTB GAAR: A Toothless Tiger or Russian Roulette? Peter Harris.
Chapter 16 CFC Rule Mario Tenore.
Chapter 17 CCCTB: Selected Issues – A Summary Mark van Graafeiland & Imme Kam.

Series: Eucotax Series on European Taxation

National Legal Presumptions and European Tax Law ISBN 9789041166135
To be published December 2017
Kluwer Law International
£127.00
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
£137.00
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
£114.00
Transfer Pricing in the US: A Practical Guide ISBN 9789041191960
Published September 2017
Kluwer Law International
£93.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed ISBN 9789041161352
Published September 2017
Kluwer Law International
£155.00
The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
£142.00
Corporate Tax Base in the Light of IAS/IFRS and EU Directive 2013/34: A Comparative Approach ISBN 9789041167453
Published July 2016
Kluwer Law International
£96.00
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
£104.00
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
£96.00
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
£112.00
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
£104.00
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
£104.00
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
£104.00
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
£110.00
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
£108.00
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
£144.00
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
£116.00
Limitation on Benefits Clauses in Double Taxation Conventions ISBN 9789041123701
Published December 2005
Kluwer Law International
Out of print
Tax Avoidance and EC Treaty Freedoms ISBN 9789041124029
Published December 2005
Kluwer Law International
£145.00
£123.00
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
£245.00
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
£189.00
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
£194.00
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
£162.00
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
£175.00
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
£171.00
The Principle of Equality in European Taxation
ISBN 9789041196934
Published December 0002
Kluwer Law International
£158.00