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Corporate Income Taxation in Europe

The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries Edited by Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck, Institute for Austrian and International Tax Law, WU, Austria
This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies.
Extent: 384 pp
Hardback Price: $162.00 Web: $145.80
Publication Date: 2013
ISBN: 978 1 78254 541 5
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  • Law - Academic
  • Corporate Law and Governance
  • European Law
  • Tax Law and Fiscal Policy
  • Law - Professional
  • Corporate Law
This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies.

The book considers the impact of the CCCTB from the perspective of non-EU-based enterprises that are carrying on business in the EU through the operation of branches or subsidiaries in member states. It incorporates the perspectives of leading scholars from all over Europe as well as from third countries such as the United States, and provides in-depth analysis of the key aspects which would affect third countries, such as: withholding taxation, taxation of transparent entities, and transfer of assets to third countries.

Corporate Income Taxation in Europe will provide essential insights to academics, practitioners and policymakers in the field of taxation. It will also interest those looking ahead to future tax reforms in the EU, or considering how a similar model may be applied elsewhere.
Contributors: K. Andersson, K. Becker, Y. Brauner, J. Englisch, D. Gutmann, C.-A. Helleputte, W. Hellerstein, C. HJI Panayi, C. Kaeser, M.A. Kane, T. Keijzer, E.C.C.M. Kemmeren, R. Lyal, G. Maisto, P. Pistone, R. Seer, D.S. Smit, C. Spengel, E. Traversa, J. van de Streek, D. Weber
Contents:

Preface

1. Taxation of EU Resident Companies under the Current CCCTB Framework: Descriptive and Critical Approach to Selected ‘Extraterritorial’ Aspects
Edoardo Traversa and Charles-Albert Helleputte

Commentaries by Krister Andersson and Katharina Becker

2. Taxation of EU-Non-Resident-Companies under the CCCTB System: Analysis and Suggestions for Improvement
Eric C.C.M Kemmeren and Daniël S. Smit

Commentary by Theo Keijzer

3. The Meaning of ‘Resident Taxpayer’ and ‘Non-Resident Taxpayer’ under the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)
Guglielmo Maisto

4. Withholding Taxation
Joachim Englisch

Commentary by Dennis Weber and Jan van de Streek

5. CCCTB and Fiscally Transparent Entities: A Third Countries’ Perspective
Yariv Brauner

Commentary by Christian Kaeser

6. Deductibility of Gifts to Charitable Bodies in Third Countries
Roman Seer

Commentary by Mitchell A. Kane

7. Transfer of Assets to Third Countries
Daniel Gutmann

8. The Limits to Interest Deductibility: An Ad Hoc Anti-abuse Rule in the Proposal for a CCCTB Directive
Pasquale Pistone

Commentary by Christoph Spengel

9. CFC Rules Within the CCCTB
Christiana HJI Panayi

Commentaries by Walter Hellerstein and Richard Lyal

Index