A Common Consolidated Corporate Tax Base for Europe — Eine by Christoph Spengel (auth.), Professor Dr. Wolfgang Schön,

By Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)

Preface This publication 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 may perhaps 2007. The convention used to be together organised by way of the German Federal Ministry of Finance, the Centre for ecu fiscal learn (ZEW), Mannheim, and the Max Planck Institute (MPI) for highbrow estate, pageant and Tax legislation, Munich. greater than 250 individuals from everywhere Europe and different areas, students, politicians, company humans and tax directors, mentioned the ecu- pean Commission’s notion to set up a CCCTB. 3 panels of tax specialists evaluated the typical tax base with admire to structural components, consolidation, allocation, foreign elements and management. The convention made transparent that the CCCTB has the aptitude to beat essentially the most fascinating difficulties of company source of revenue taxation in the universal marketplace. universal tax accounting principles considerably lessen compliance and administrative expenses. Consolidation of a group’s gains and losses results cro- border loss reimbursement which gets rid of a tremendous tax problem for eu cro- border funding. even as, tax making plans with admire to financing and move pricing is driven again in the eu Union. additionally, so far as the CCCTB applies, member states may be able to eliminate tax provisions which are certain at move border tax evasion and that will be challenged via the jurisdiction of the ecu- pean court docket of Justice.

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Real profits exceeding the assumed market interest rate) as a dividend. In each case, the parent needs to raise funds itself, and this is done by its own shareholders which are supposed to be natural persons. 21 Intangibles Buildings Machinery Financial Assets Inventories 45 Investments 5 Assets Subsidiary 3 Sources of Finance Debt Retained Earnings Dividends Retained Dividends Earnings Dividends Interest Dividends Equity Dividends Parent Company 3 Sources of Finance Debt Interest Dividends External Funds Equity Shareholders (Not considered here) Capital Market Figure 12: Outline of the model The consideration of five types of assets at the level of the subsidiary and three sources of finance at both the level of the subsidiary and the parent company results in 45 possible combinations of assets and financing for both the level of the subsidiary and the level of the parent.

Finally, there are intensified controls, corrections and documentation requirements relating to intragroup transfer prices, but only to the extent that the contracting unit is a foreign subsidiary or a permanent establishment. Substantial elements of these tax provisions contravene the ban on discrimination and may violate the fundamental freedoms laid down in the EC Treaty, in particular the freedom of establishment (Article 43 EC Treaty) and the free movement of capital (Article 56 EC Treaty).

2. 22 Christoph Spengel finance of the subsidiary provided by the parent company. Subsidiaries (outbound investment) and parent companies (inbound investment) are located in the remaining 26 member states. 40 35 EATR in % 30 25 20 15 10 5 Cyprus t ty eb D gs ui in rn Ea ew N d ne ai et R et R Inbound Eq t ty eb D gs ui in Ea d ne ai N D ew rn es om D ai et R Outbound Eq tic t eb ty gs in rn Eq Ea ew N d ui t ty eb D ne Ea ui in N d R et ai ne ew rn es om D Eq tic gs 0 Outbound Inbound Spain Figure 16: Cross-border investment – highest and lowest level From the perspective of low tax countries (here: Cyprus), parent companies located therein have no incentives to invest abroad from a tax point of view.

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