CCCTB

Common Consolidated Tax Base – An EU project under which corporations will file one consolidated tax return in Europe.

BEPS, CCCTB, EU/EEA, OECD

(Catholic University in Italy; Maisto & Associati)/ /Leave a comment

This contribution lays down a general plan for what the EU should do in order to attain a harmonized set of norms regulating the allocation of taxing rights among Member States and in the relation between those States and third countries, which would benefit both Member States and their taxpayers by eliminating several instances of…

CCCTB, Tax Credits, Tax Planning, Tax Treaties, Withholding Taxes

(International tax professional)/ /Leave a comment

There are several misconceptions in international taxation, some of them more pervasive than others.  Many are often repeated by speakers at tax conferences without being contradicted. The first is the so-called interest deduction bias.  It is not the main topic of this blog, but I will deal with it by way of introduction. The Interest…

BEPS, CCCTB, EU/EEA, OECD, Tax Policy

(Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome)/ /Leave a comment

Italy has embarked upon the challenging task of redesigning its tax system.  The Act[1] of late November 2016 (hereinafter, “Act”) constitutes a best-practices example, or at least for our Country. The above Act illustrates the national fiscal policy for the coming 3-year period, i.e., for 2017 – 2019, specifying the primary objectives and the guidelines…

CCCTB, EU/EEA, Tax Policy

(Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome)/ /Leave a comment

A global silver alert for fair and efficient tax systems is active already for a couple of years. The heated debate sparked all over the world has engaged national governments, NGOs, international organizations as well as each and every taxpayer – or tax evader. The EU has been driving the discussions and – most importantly…

CCCTB, EU/EEA, OECD, Permanent Establishments

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam, EU Direct Tax Group (EUDTG) PwC)/ /1 Comment

The Anti-Tax Avoidance Directive (ATAD) is the European answer to the phenomenon of BEPS: Base Erosion and Profit Shifting. Characteristically for tax avoidance by Base Erosion and Profit Shifting, is that it takes place within multinational groups (MNE’s). Therefore, the ATAD applies to these groups of companies. Nevertheless, the European Commission has chosen to also…

CCCTB, EU/EEA

(Dorean Global Tax Policy BV)/ /2 Comments

Introduction. I have been actively supporting an EU based corporate income tax to reflect the single internal market rather than a fragmented framework with 28 competing tax laws. I’ve done so since the early 1990’s, after the publication of the Ruding Report (following earlier proposals by eg. Van den Tempel).  The CCCTB approach as introduced…

BEPS, CCCTB, EU/EEA, Tax Avoidance, Tax Policy

(Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff)/ /Leave a comment

(about the switch-over clause in the ATA Directive) In order to combat BEPS, the European Commission is proposing to start taxing low taxed non-EU income. That sounds reasonable, but the consequence will be that in the EU, there will be no more profits to tax. This is a proposal that is not necessary to prevent…

BEPS, CCCTB, EU/EEA, Residence, Tax Planning, Tax Treaties

(Mircea and Partners Law Firm)/ /Leave a comment

The raison d’être of corporate taxation relates to the aim of achieving an impartial treatment of different legal forms in order to safeguard a level playing field for conducting business. In the EU this aim must be contemplated in conjunction with the objective of establishing an internal market free of fiscal barriers. The present post…

BEPS, CCCTB, EU/EEA, OECD, Tax Avoidance, Tax Planning, Tax Policy

(CORIT advisory)/ /2 Comments

Written by Associate Professor, PhD, Michael Tell, Department of Law, Copenhagen Business School and Technical Advisor, CORIT Advisory. Darwin’s theory of evolution states that complex creatures evolve from more simplistic ancestors, while natural selection ensures that only the fittest survive and the others become evolutionary “dead-ends”. The aim of this blog contribution is to address…

CCCTB

(PhD Researcher, University of Amsterdam)/ /Leave a comment

0n June 17 2015, the Commission re-launched the CCCTB Directive after being four years discussions in the Council of the European Union. In 2016 the Commission will issue a completely new CCCTB Directive Proposal, with several major changes comparing to the original proposal issued in 2011. In the re-launch announcement, the Commission takes a realistic…

CCCTB, EU/EEA, MAPs and APAs, State Aid

(Dorean Global Tax Policy BV)/ /2 Comments

Let’s go back a few weeks, to March 18, 2015. The EU Commission announces its much heralded Tax Transparency package. The package contains a surprise element: the link to the Code of Conduct Report of 1999. To refresh memories: this report, lead by a UK national, contained 66 harmful tax measures. The 66 could be…

CCCTB, EU/EEA, State Aid

(CORIT advisory)/ /1 Comment

It is well known that the world’s economies have turned into a global economy during the last decades. Moreover, it is nowadays common knowledge – also outside the professional tax community – that states are fighting each other for tax revenue, while multinationals are trying to reduce their tax burden through tax planning that may…