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Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions.

Corporations, Foreign --- Income tax --- International business enterprises --- Corporations --- Taxation --- Foreign income --- Law and legislation --- Corporations, Foreign - Taxation --- Income tax - Foreign income --- International business enterprises - Taxation --- Corporations - Taxation - European Union countries --- Taxation - Law and legislation - European Union countries

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Company taxation is an important element for the establishment and the completion of the Internal Market. Against this background, the European Commission recommends the harmonisation of the tax base in the European Union. Carsten Wendt analyses the necessity, the concept as well as potential advantages and effects of a common tax base for multinational enterprises in the European Union. He addresses important issues concerning a common tax base, such as the definition of the consolidated group, the technique and scope of consolidation and the formula used to allocate the consolidated tax base among the involved member states. The author provides alternative options to solve these issues and concludes that a common tax base as intended by the European Commission would remedy many of the existing tax obstacles for multinational enterprises in the EU. However, distortions will remain, mainly because member states retain their sovereignty to set their tax rates independently and the territorial scope of a common tax base has to be restricted to group entities located within the EU.

Capital -- Mathematical models. --- Capital investments -- Mathematical models. --- Corporations -- Taxation -- European Union countries. --- Corporations -- Taxation. --- Commerce --- Management --- Business & Economics --- Accounting --- Industrial Management --- International business enterprises --- Taxation --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business. --- Tax accounting. --- Tax laws. --- Business and Management. --- Business Taxation/Tax Law. --- Business enterprises --- Corporations --- Joint ventures --- Finance, Public --- Tax laws --- Tax legislation --- Tax regulations --- Law

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#SBIB:33H13 --- #SBIB:327.7H231 --- #SBIB:HIVA --- EEC / European Union - EU -Europese Unie - Union Européenne - UE --- 336.214 --- 334.151.3 --- 336.201 --- Economische politiek --- Europese Unie: sociaal-economisch beleid, landbouw-, milieu-, cultuur- en communicatiebeleid --- Belastingstelsel van de genootschappen. --- EG : begrotings- en belastingpolitiek. --- Fiscaal regime: structuur en evolutie. Fiscale hervorming. --- Corporations --- Taxation --- European Union countries --- Corporations - Taxation - European Union countries. --- Business corporations --- C corporations --- Corporations, Business --- Corporations, Public --- Limited companies --- Publicly held corporations --- Publicly traded corporations --- Public limited companies --- Stock corporations --- Subchapter C corporations --- EG : begrotings- en belastingpolitiek --- Fiscaal regime: structuur en evolutie. Fiscale hervorming --- Belastingstelsel van de genootschappen --- Business enterprises --- Corporate power --- Disincorporation --- Stocks --- Trusts, Industrial

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Even though multinational companies doing business across the European Union generally operate at the EU level, they must still compute a separate company tax base for each Member State where they do business. This process creates enormous compliance burdens as integrated multinational enterprises struggle to find appropriate "arm’s length" prices for their internal transfers of goods, services and intangibles. This process fails to tax EU companies in a manner consistent with how they do business in the European Union. By contrast to this system of separate acounting with arm’s length pricing, consolidated base taxation with formulary apportionment is an ideal system to apply to tax multinational enterprises in the European Union. Company Tax Reform in the European Union. Guidance from the United States and Canada on Implementing Formulary Apportionment in the EU draws from experiences in the U.S. states and Canadian provinces to provide guidance to the European Union. The book describes the new landscape for company tax reform in the EU and how formulary apportionment fits into that landscape. It discusses practical issues concerning the fundamental elements of a formulary apportionment system and evaluates technical issues concerning how formulary apportionment may affect investment, employment, tax planning, and tax competition in the European Union. The book emphasizes that formulary apportionment preserves EU Member State tax sovereignty and allows them to remain competitive in the drive to stimulate new investment and employment. "Dr. Martens-Weiner's book draws on the U.S. and Canadian experience in using formulary apportionment to achieve a reasonable allocation of income across fiscal borders. The lessons she draws should inform the EU debate over formulary apportionment." Emil M. Sunley, Assistant Director Fiscal Affairs Department, International Monetary Fund "Company Tax Reform in the European Union gave me new insights on the U.S. and Canadian experiences with formulary allocation of business income. Reading it will be a must for anybody who wants to take part in the forthcoming discussion of the future common consolidated corporate tax base and its formula allocation to different EU Member States." Dr. Albert J. Rädler Prof. em. of International Business Taxation, International Tax Institute, University of Hamburg Senior Tax Partner, Linklaters Oppenhoff & Rädler, Munich office Member of the Ruding Committee, Brussels 1991/1992 "An important volume that will prove valuable as the European Union decides whether -- and how -- to harmonize company income taxes." Charles E. McLure, Jr. Hoover Institution, Stanford University "This book is important reading for both tax policymakers and business leaders. It breaks the mold of conventional thinking by demonstrating that formulary apportionment is a practical way to solve the income-allocation problems confronting the European Union. Equally important, the book gives the advocates of arm’s-length allocation methods some challenging food for thought." Thomas F. Field Founder, Tax Analysts Joann Martens-Weiner is a renowned world expert on formulary apportionment. She has dedicated more than 15 years to the subject, beginning with her dissertation on the economic effects of the formulary apportionment system used in the United States and Canada. Dr. Martens-Weiner has a Ph.D. in economics from Harvard University and a B.S. in Business Administration from the University of California at Berkeley. She has served as an economist in the Office of Tax Analysis at the U.S. Treasury Department and as an expert on formulary apportionment for the Directorate-General for Taxation and Customs Union at the European Commission.

Corporations --- International business enterprises --- Taxation --- 336.2 EU --- EEC / European Union - EU -Europese Unie - Union Européenne - UE --- 336.214 --- 334.151.3 --- Belastingen. Belastingswezen. Openbare financien. Belastingspolitiek. Belastingstheorie. Belastingsharmonisatie. Fiskale politiek. Belastingsleer. Belastingsdruk. Belastingstechniek. Belastingsstelsel.Belastingstarief--EU --- Belastingstelsel van de genootschappen. --- EG : begrotings- en belastingpolitiek. --- Intergovernmental fiscal relations --- Sociétés --- Entreprises multinationales --- Relations fiscales intergouvernementales --- Impôts --- EPUB-LIV-FT LIVECONO LIVGESTI SPRINGER-B --- Business enterprises, International --- Corporations, International --- Global corporations --- International corporations --- MNEs (International business enterprises) --- Multinational corporations --- Multinational enterprises --- Transnational corporations --- Business corporations --- C corporations --- Corporations, Business --- Corporations, Public --- Limited companies --- Publicly held corporations --- Publicly traded corporations --- Public limited companies --- Stock corporations --- Subchapter C corporations --- Business enterprises --- Joint ventures --- Corporate power --- Disincorporation --- Stocks --- Trusts, Industrial --- EG : begrotings- en belastingpolitiek --- Belastingstelsel van de genootschappen --- Corporations - Taxation - European Union countries. --- Corporations - Taxation - United States. --- Corporations - Taxation - Canada. --- International business enterprises - Taxation - Europe. --- Acqui 2006