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The European Commission’s proposed Common Consolidated Corporate Tax Base
(CCCTB) is the most ambitious project in the history of direct taxation within
the EU. While retaining the right of Member States to set their own corporate
tax rate, the proposed system allows for a ‘one-stopshop’ for filing tax
returns and consolidating prof its and losses across the EU. In this book –
the first to offer guidance to practitioners whose work will be affected by
these new developments – 19 prominent representatives of the business
community, tax consultancy, academic taxation scholarship and tax
administration discuss the proposed system’s rationale, structure and
uncertainties, ranging from very technical aspects, to the wording of the
proposal, to political considerations. These topics include the following: ;
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the concept of ‘permanent establishment’;
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‘dual resident’ companies;
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consequences of entering and leaving;
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depreciation of fixed assets;
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repackaged asset transfers;
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disagreements among Member States;
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subsidiarity and the ‘yellow card procedure’;
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international aspects and tax treaties;
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sharing mechanism and transfer pricing; and
The discussion raises numerous issues likely to lead to future amendments, and
for this reason, along with its practical value in developing an understanding
of the proposed system’s specif ic effects, the book will be welcomed by tax
consultants and lawyers worldwide, corporate tax advisers, European tax
authorities and tax researchers and academics.
List of Contributors. Preface. Chapter 1 Consolidation in the CCCTB
Proposal 1 Thies Sanders. Chapter 2 Relevant Aspects When
Entering the System/CCCTB Group Paul H.M. Simonis. Chapter 3
Business Reorganisations within the Group Bertil Wiman. Chapter 4
Leaving a Group Jan van de Streek. Chapter 5 CCCTB: General
Principles and Characteristics Ronald Russo. Chapter 6
Depreciation Rules under the Proposed CCCTB Directive 79 Hein Vermeulen
. Chapter 7 Is the CCCTB Proposal in line with the Principle of
Subsidiarity?: Negative Opinions Submitted by National Parliaments in the
‘Yellow Card Procedure’ Rita Szudoczky. Chapter 8
The One-Stop-Shop Approach: A Discussion of the Administrative and Procedural
Aspects of the CCCTB Draft Directive J.A.R. van Eijsden. Chapter 9
Appeals Daniel Gutmann. Chapter 10 The Common Consolidated
Corporate Tax Base and the Future of Taxation Theo Keijzer. Chapter
11Withholding Taxes and Relief for Double Taxation Matthijs Vogel.
Chapter 12 Common Consolidated Corporate Tax Base: The Sharing Mechanism,
Some General Considerations Antonio Russo. Chapter 13 Tax Planning
under the CCCTB’s Formulary Apportionment Provisions: The Good, the Bad and
the Ugly Walter Hellerstein. Chapter 14 CCCTB and Formulary
Apportionment: The European Commission Finds the Right Formula Joann
Martens Weiner. Chapter 15 The CCCTB GAAR: A Toothless Tiger or
Russian Roulette? Peter Harris. Chapter 16 CFC Rule Mario
Tenore. Chapter 17 CCCTB: Selected Issues – A Summary Mark
van Graafeiland & Imme Kam.