The EU Common Consolidated Corporate Tax Base —— Critical Analysis

----- 欧盟共同合并企业税基：批判性分析

ISBN: 9789041192332 出版年：2016 页码：274 Kluwer Law International

In October 2016, the European Commission relaunched its plan to harmonize national income tax systems via the Common Consolidated Corporate Tax Base (CCCTB), perhaps the most ambitious reform of EU tax law ever attempted. This timely book offers an early analysis of this important proposal and its implications, covering issues such as the project’s scope and main elements, international considerations, the relationship with OECD’s base erosion and profit shifting (BEPS) initiative, consolidation, and anti-abuse rules. With carefully selected papers first presented at a January 2017 conference hosted by the Amsterdam Centre for Tax Law, this volume focuses on such topics and issues as the following:– ways in which the proposed CCCTB is designed to preserve the competence of Member States to set their own tax rates; – reduction of the administrative burden for multinational companies;– incentives for research and development;– automatic cross-border relief within the EU;– detailed analysis of the proposal’s formula apportionment regime;– proposed new controlled foreign company (CFC) rules; and– interest limitation rule.Because of the commitment of many Member States to keep their corporate income tax systems competitive on a stand-alone basis, the proposed CCCTB is enormously controversial. This book provides authoritative insights into problems likely to arise and discusses the prospects of how the proposal is likely to be implemented. Thus, this book proves to be of immeasurable value to taxation policymakers, practitioners, and academics.