By Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)
Preface This booklet includes the lawsuits of the overseas Tax convention at the c- th th mon consolidated company tax base (CCCTB) that used to be held in Berlin on 15 – sixteen might 2007. The convention used to be together organised by means of the German Federal Ministry of Finance, the Centre for ecu fiscal learn (ZEW), Mannheim, and the Max Planck Institute (MPI) for highbrow estate, festival and Tax legislation, Munich. greater than 250 individuals from in every single place Europe and different areas, students, politicians, enterprise humans and tax directors, mentioned the ecu- pean Commission’s suggestion to set up a CCCTB. 3 panels of tax specialists evaluated the typical tax base with admire to structural parts, consolidation, allocation, foreign points and management. The convention made transparent that the CCCTB has the capability to beat probably the most exciting difficulties of company source of revenue taxation in the universal industry. universal tax accounting ideas considerably lessen compliance and administrative expenditures. Consolidation of a group’s gains and losses results cro- border loss reimbursement which gets rid of an important tax crisis for ecu cro- border funding. even as, tax making plans with recognize to financing and move pricing is driven again in the ecu Union. furthermore, so far as the CCCTB applies, member states may be able to get rid of tax provisions which are special at pass border tax evasion and that would be challenged by way of 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
In defining the group, the underlying rationale for the CCCTB has to be kept in mind. 53 Legal ownership is widely recognised as a key element in defining the taxable unit both in 52 53 See Oestreicher/Spengel, European Taxation 2007, pp. 437-451; Gammie/Giannini/Klemm/ Oestreicher/Parascandolo/Spengel, Achieving a Common Consolidated Corporate Tax Base in the EU, Centre for European Policy Studies (CEPS), Brussels 2005; see also the contribution of Wolfgang Schön in this volume. See Hellerstein/McLure, International Tax and Public Finance 2004, p.
An inclusion of transparent entities would also affect revenues from personal income tax. The fiscal effects of consolidation and formula apportionment could not be limited to corporate income tax. These effects are not intended by the European Commission, as the proposals for a consolidated tax base focus on corporate income tax rather than on personal income tax. 67 Although transparent entities should not qualify for the application of the CCCTB, they are still relevant. If a corporation included in the personal scope of the CCCTB is a partner of a transparent entity, its share of the income of the transparent entity should be included in the CCCTB.
There is a wide range of EATR within the member states (Figure 14). 50 per cent). 13 per cent. e. the number of taxes, the tax bases and the tax rates). However, the statutory (nominal) tax rate on corporate profits plays an important role in determining the EATR. The ranking of the countries based on the nominal tax rates on corporate profits is a good indicator of the ranking with respect to the EATR. Here, there would be few changes in the country ranking (Figure 14). This is because the 20 Christoph Spengel calculations of effective company tax burdens concentrate on profitable investments and only few member states levy substantial non-profit taxes.
A Common Consolidated Corporate Tax Base for Europe — Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa by Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)