A Common Consolidated Corporate Tax Base for Europe — Eine by Christoph Spengel (auth.), Professor Dr. Wolfgang Schön,

By Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)

Preface This publication comprises the lawsuits of the foreign Tax convention at the c- th th mon consolidated company tax base (CCCTB) that used to be held in Berlin on 15 – sixteen may possibly 2007. The convention used to be together organised through the German Federal Ministry of Finance, the Centre for ecu monetary examine (ZEW), Mannheim, and the Max Planck Institute (MPI) for highbrow estate, festival and Tax legislations, Munich. greater than 250 individuals from all over the place Europe and different areas, students, politicians, enterprise humans and tax directors, mentioned the european- pean Commission’s thought to set up a CCCTB. 3 panels of tax specialists evaluated the typical tax base with recognize to structural components, consolidation, allocation, overseas facets and management. The convention made transparent that the CCCTB has the aptitude to beat the most exciting difficulties of company source of revenue taxation in the universal industry. universal tax accounting ideas considerably decrease compliance and administrative expenditures. Consolidation of a group’s earnings and losses results cro- border loss reimbursement which gets rid of an immense tax drawback for eu cro- border funding. whilst, tax making plans with appreciate to financing and move pricing is driven again in the eu Union. additionally, so far as the CCCTB applies, member states may be able to get rid of tax provisions which are unique at go border tax evasion and that would be challenged via the jurisdiction of the ecu- pean court docket of Justice.

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Extra info for A Common Consolidated Corporate Tax Base for Europe — Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa

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This is necessary to ensure the taxation of net income. Two possible mechanisms 69 70 71 See Regulation (EU) 1606/2002 by the European Parliament and the Council regarding the application of International Accounting Standards, OJ L 243/1. See European Commission, An Internal Market without company tax obstacles – achievements, ongoing initiatives and remaining challenges, Communication from the Commission to the Council, the European Parliament and the European Economic and Social Committee, Brussels 2003.

2. 22 Christoph Spengel finance of the subsidiary provided by the parent company. Subsidiaries (outbound investment) and parent companies (inbound investment) are located in the remaining 26 member states. 40 35 EATR in % 30 25 20 15 10 5 Cyprus t ty eb D gs ui in rn Ea ew N d ne ai et R et R Inbound Eq t ty eb D gs ui in Ea d ne ai N D ew rn es om D ai et R Outbound Eq tic t eb ty gs in rn Eq Ea ew N d ui t ty eb D ne Ea ui in N d R et ai ne ew rn es om D Eq tic gs 0 Outbound Inbound Spain Figure 16: Cross-border investment – highest and lowest level From the perspective of low tax countries (here: Cyprus), parent companies located therein have no incentives to invest abroad from a tax point of view.

205. See Agúndez-García, The Delination and Apportionment of an EU Consolidated Tax Base for Multi-Jurisdictional Corporate Income Taxation: A Review of Issues and Options, Taxation Papers, Brussels 2006, p. 13; Jacobs/Spengel/Schäfer, Intertax 2004, pp. 277-278; Martens Weiner, Company Tax Reform in the European Union. Guidance from the United States and Canada on Implementing Formulary Apportionment in the EU, New York 2006, p. 71. See Hellerstein/McLure, International Tax and Public Finance 2004, pp.

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