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Selectivity in State Aid Law and the Methods for the Allocation of the Corporate Tax Base


ISBN13: 9789041194138
Published: June 2018
Publisher: Kluwer Law International
Country of Publication: The Netherlands
Format: Hardback
Price: £111.00



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Selectivity in State Aid Law and the Methods for the Allocation of the Corporate Tax Base analyses the theoretical issues that arise when applying the selectivity test in State aid law to three methods for the allocation of the corporate tax base between the members of multinational enterprises.

Indeed, High-profile cases before the European Commission and the EU courts have indeed intensified scrutiny of the link between State aid law and the taxation of multinational enterprises. Certain decisions have raised questions about fiscal sovereignty and the interpretation of the rules on State aid – in particular the notion of selectivity – which have not been addressed in detail by the existing research.

The combination of the evolution of the notion of selectivity in State aid law, on the one hand, and the need to adapt the rules for the taxation of the profits of multinational enterprises to the modern economy, on the other hand, makes it necessary to assess whether existing, as well as alternative rules for the allocation of the corporate tax base might entail a selective treatment.

What’s in this book:

This book responds to the need for research in the area of State aid law applied to taxation of the income of multinational enterprises, focusing on the crucial concept of selectivity. The analysis proceeds with a detailed investigation of the application of the selectivity test in State aid law to three methods for the allocation of the corporate tax base between the members of multinational enterprises:

  • the arm’s length principle;
  • transfer pricing safe harbours; and
  • systems of formula apportionment.
This research project is conducted at a theoretical level, without considering national provisions or particular tax treaties. The author suggests an analytical framework on the application of the selectivity test to the three allocation methods. It is concluded that these methods are likely to have certain selective features, with varying possibilities to be justified by the inner logic of a corporate income tax system. It is also demonstrated that selectivity occurs for different reasons, due to the different rationales of the three allocation methods.

How this will help you:

This well-researched book is intended at contributing to the academic literature on the impact of State aid law on the principles for the taxation of the income of multinational enterprises. The outcome of this research project is also relevant to lawmakers who need to reconcile the imperatives of State aid law with the design of rules that match their tax policies, and to judges or lawyers who apply the rules on State aid to tax provisions.

Subjects:
Taxation
Contents:
About the Author
Foreword
Preface
List of Abbreviations
CHAPTER 1
Introduction
PART I
Elements of the Selectivity Test That Are Common to the Three Allocation Methods
CHAPTER 2
Determination of the Reference System
CHAPTER 3
Potential Relevance of the Market Economy Operator Test
CHAPTER 4
Comparability Analysis
PART II
Selectivity Assessment of the Three Allocation Methods
CHAPTER 5
Prima Facie Selectivity of a Generally Formulated Arm’s Length Provision
CHAPTER 6
Prima Facie Selectivity of Transfer Pricing Safe Harbours
CHAPTER 7
Prima Facie Selectivity of a System of Formula Apportionment with Firm-Specific Factors
CHAPTER 8
The Justification and Proportionality Tests
CHAPTER 9
Conclusion
Bibliography
Table of Cases
Table of Legislation
European Commission
OECD Council Recommendations
Index

Series: EUCOTAX Series on European Taxation

Aggrieved Taxpayers versus Tax Authorities ISBN 9789403522081
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Special Tax Zones and EU Law: Theory, Implementations and Future Challenges ISBN 9789403518855
Published January 2020
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European VAT and the Sharing Economy ISBN 9789403514352
Published October 2019
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£116.00
£86.00
Sales Promotion Techniques and VAT in the EU ISBN 9789403508610
Published March 2019
Kluwer Law International
£115.00
Investment Fund Taxation: Domestic Law, EU Law, and Double Taxation Treaties ISBN 9789041196699
Published May 2018
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£107.00
National Legal Presumptions and European Tax Law ISBN 9789041166135
Published February 2018
Kluwer Law International
£154.00
Double (Non-) Taxation and EU Law ISBN 9789041194107
Published November 2017
Kluwer Law International
£167.00
EU Citizenship and Direct Taxation ISBN 9789041185846
Published October 2017
Kluwer Law International
£139.00
Transfer Pricing in the US: A Practical Guide ISBN 9789041191960
Published September 2017
Kluwer Law International
£113.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed ISBN 9789041161352
Published September 2017
Kluwer Law International
£188.00
Limitation on Benefits Clauses in Double Taxation Conventions 2nd ed (eBook) ISBN 9789041161437
Published September 2017
Kluwer Law International
£188.00
(ePub)
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The Impact of Tax Treaties and EU Law on Group Taxation Regimes ISBN 9789041169051
Published August 2016
Kluwer Law International
£211.00
£142.00
(ePub)
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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
£142.00
Tax Treaty Override ISBN 9789041154064
Published April 2014
Kluwer Law International
£167.00
Fixed Establishments in European VAT ISBN 9789041145543
Published August 2013
Kluwer Law International
£154.00
CCCTB: Common Consolidated Corporate Tax Base - Selected Issues (EUCOTAX 35)
Edited by: Dennis Weber
ISBN 9789041138729
Published May 2012
Kluwer Law International
£178.00
Intermediation of Insurance & Financial Services in European VAT ISBN 9789041137326
Published August 2011
Kluwer Law International
£178.00
From Marks & Spencer to X Holding: The Future of Cross-Border Group Taxation ISBN 9789041133991
Published August 2011
Kluwer Law International
£167.00
Fiscal Sovereignty of the Member States in an Internal Market: Past and Future ISBN 9789041134035
Published December 2010
Kluwer Law International
£167.00
Europe-China Tax Treaties ISBN 9789041132161
Published June 2010
Kluwer Law International
£167.00
Taxation of Ucits: Austria Germany the Netherlands and the Uk ISBN 9789041128393
Published October 2009
Kluwer Law International
£173.00
Integration Approaches to Group Taxation in European Internal Market ISBN 9789041127792
Published October 2008
Kluwer Law International
£167.00
Tax Compliance Costs for Companies in an Enlarged European Community ISBN 9789041126665
Published May 2008
Kluwer Law International
£224.00
ECJ-Recent Developments in Direct Taxation ISBN 9789041125095
Published March 2006
Kluwer Law International
£177.00
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
£222.00
WTO and Direct Taxation ISBN 9789041123718
Published May 2005
Kluwer Law International
£374.00
£187.00
Tax Competition and EU Law
Carlo PintoResearch Associate, Department of Law, University of Amsterdam, Netherlands
ISBN 9789041199133
Published May 2003
Kluwer Law International
£290.00
Settlement of Disputes in Tax Treaty Law ISBN 9789041199041
Published September 2002
Kluwer Law International
£298.00
Tax Treaty Interpretation
Edited by: Michael Lang
ISBN 9789041198570
Published June 2002
Kluwer Law International
£249.00
The Impact of Community Law on Tax Treaties: Issues and Solutions ISBN 9789041198600
Published February 2002
Kluwer Law International
£268.00
The Principle of Equality in European Taxation ISBN 9789041196934
Published October 1999
Kluwer Law International
£243.00
The Compatibility of Anti-abuse Provisions in Tax Treaties with EC Law
ISBN 9789041196781
Published January 1999
Kluwer Law International
£262.00