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The creation of a group taxation framework to subject affiliated
entities resident in more than one EC Member State to a single set of rules is
an experiment without precedent. Group taxation normally deals with tax
liability in the context of a single jurisdiction. There is no system of group
taxation worldwide which embraces more than one fiscal jurisdiction under a
single regulatory umbrella.
This thought provoking work explores the prospect for creating a group
taxation system extending across national borders in the EC. The objective is
to specify what shape the elements of such a system should take as well as to
identify the areas of complexity or probable impasse.
Among the topics covered...
The relevant jurisprudential and legislative framework of the European
A survey of the tax systems of Canada, Switzerland and the US with a focus on
the principles pertaining to the division of power between the federal and
The policies for corporate taxation in integrated markets;
Administrative concerns: compliance, enforcement, dispute resolution and
re-assessment of tax liability;
Tests for entitlement to group membership;
Tax base integration; - Territorial delineation of the group; and
In sum, this book provides valuable insights into an area of significant
importance to taxpayers, their advisors and policymakers as well.
Dedication. Acknowledgements. Introduction. 1. The Jurisprudence
of the ECJ Relevant to Groups 2. Positive Integration Relevant to Groups
3. Deriving Examples from Corporate Tax Systems at Sub-Federal Level:
Canada, Switzerland and the United States of America 4. Policy
Approaches to Corporation Taxes in Closely Integrated Markets 5.
Entitlement to Membership of the Group 6. The Group Tax Base 7.
International Aspects 8. Formulary Apportionment 9.
Administrative Issues. Bringing Together the Elements of the Scheme.
Bibliography. Legislation. Policy Documents. List of Cases