From Marks and Spencer to X Holding: The Future of Cross-Border Group Taxation
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- Synopsis
- Group taxation – special schemes according to which a group of companies meeting certain requirements may be assimilated for tax purposes to a single company – exists in several European Member States and is now under consideration in an EU proposal concerning a common consolidated corporate tax base (CCCTB). Its rationale as a potential EU tax regime has arisen from a series of high-profile ECJ cases concerning cross-border tax relief claims – decisions which have been criticized for lack of clarity and for breach of freedom of establishment (Article 49 TFEU). Group taxation has now become one of the most intensively debated issues in EU tax law. The papers collected in this timely book derive from an ACTL Seminar held at Amsterdam in April 2010. The thirteen authors are either well-known practitioners from major law firms and accounting firms, or noted European tax scholars, or both. Among the central issues covered in the book are the following: the underlying tax obstacles which exist for companies operating in more than one Member State; potential for tax avoidance; prevention of double use of losses (the ‘no possibilities’ test); disadvantages that arise as a consequence of the parallel exercise of fiscal sovereignty; the concept of ‘balanced allocation of taxing powers’; meaning of ‘final losses’; the ‘Bosal fix’; cash-flow disadvantages of having to carry losses forward; deduction of currency losses; deduction-and-recapture rules; and VAT grouping.
- Copyright:
- 2011
Book Details
- Book Quality:
- Publisher Quality
- Book Size:
- 248 Pages
- ISBN-13:
- 9789041134783
- Related ISBNs:
- 9789041133991
- Publisher:
- Wolters Kluwer
- Date of Addition:
- 07/28/21
- Copyrighted By:
- Kluwer Law International BV, The Netherlands
- Adult content:
- No
- Language:
- English
- Has Image Descriptions:
- No
- Categories:
- Nonfiction, Business and Finance, Law, Legal Issues and Ethics
- Submitted By:
- Bookshare Staff
- Usage Restrictions:
- This is a copyrighted book.
- Edited by:
- Dennis Weber
- Edited by:
- Bruno Da Silva
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