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The EU Common Consolidated Corporate Tax Base: Critical Analysis

Edited by: Dennis Weber, Jan van de Streek

ISBN13: 9789041192332
Published: December 2017
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £109.00



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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.

Subjects:
Taxation
Contents:
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