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Books > Law > Laws of other jurisdictions & general law > Financial, taxation, commercial, industrial law > Financial law > Taxation law
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From Marks and Spencer to X Holding - The Future of Cross-Border Group Taxation (Hardcover)
Loot Price: R3,650
Discovery Miles 36 500
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From Marks and Spencer to X Holding - The Future of Cross-Border Group Taxation (Hardcover)
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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.
General
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