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The Asian-Pacific countries as well as India and Russia offer
multinational companies all the benefits of booming economies in a
world of recession. However, the investor must be aware of the tax
regime under which he will operate. This survey presents the rates,
definitions of taxable income and the incentives available in a
complete, yet concise form. It goes on to review tax minimisation
strategies and concludes with a comparison of the overall tax
burdens for investors in each country derived from the
Devereux/Griffith formulae - a methodology well known within the
EU, but applied to this region for the first time.
Preface This book contains the proceedings of the International Tax
Conference on the c- th th mon consolidated corporate tax base
(CCCTB) that was held in Berlin on 15 - 16 may 2007. The conference
was jointly organised by the German Federal Ministry of Finance,
the Centre for European Economic Research (ZEW), Mannheim, and the
Max Planck Institute (MPI) for Intellectual Property, Competition
and Tax Law, Munich. More than 250 participants from all over
Europe and other regions, scholars, politicians, business people
and tax administrators, discussed the Eu- pean Commission's
proposal to establish a CCCTB. Three panels of tax experts
evaluated the common tax base with respect to structural elements,
consolidation, allocation, international aspects and
administration. The conference made clear that the CCCTB has the
potential to overcome some of the most intriguing problems of
corporate income taxation within the Common Market. Common tax
accounting rules substantially reduce compliance and administrative
costs. Consolidation of a group's profits and losses effects cro-
border loss compensation which removes a major tax obstacle for
European cro- border investment. At the same time, tax planning
with respect to financing and transfer pricing is pushed back
within the European Union. Moreover, as far as the CCCTB applies,
member states are able to remove tax provisions that are targeted
at cross border tax evasion and that might be challenged by the
jurisdiction of the Eu- pean Court of Justice.
The study conducted by the Centre of European Economic Research
(ZEW), the University of Mannheim and Ernst & Young contributes
to the ongoing evaluation of the proposal for a Draft Council
Directive on a Common Consolidated Corporate Tax Base (CC(C)TB)
released by the European Commission on March 16, 2011. For the
first time, details on the determination of taxable income under
the proposed Council Directive are compared to prevailing corporate
tax accounting regulations in all 27 Member States, Switzerland and
the US. The study presents evidence on the scope of differences and
similarities between national tax accounting regulations and the
Directive's treatment in a complete, yet concise form. Based on
this comprehensive comparison, it goes on to discuss remaining open
questions and adjustments needed if the Directive is to be
implemented in national tax law. Readers seeking a basis for taking
an active part in the public debate will find a valuable source of
information and a first impression of how the proposed CC(C)TB
would affect corporate tax burdens in the European Union.
The Asian-Pacific countries as well as India and Russia offer
multinational companies all the benefits of booming economies in a
world of recession. However, the investor must be aware of the tax
regime under which he will operate. This survey presents the rates,
definitions of taxable income and the incentives available in a
complete, yet concise form. It goes on to review tax minimisation
strategies and concludes with a comparison of the overall tax
burdens for investors in each country derived from the
Devereux/Griffith formulae - a methodology well known within the
EU, but applied to this region for the first time.
The study conducted by the Centre of European Economic Research
(ZEW), the University of Mannheim and Ernst & Young contributes
to the ongoing evaluation of the proposal for a Draft Council
Directive on a Common Consolidated Corporate Tax Base (CC(C)TB)
released by the European Commission on March 16, 2011. For the
first time, details on the determination of taxable income under
the proposed Council Directive are compared to prevailing corporate
tax accounting regulations in all 27 Member States, Switzerland and
the US. The study presents evidence on the scope of differences and
similarities between national tax accounting regulations and the
Directive's treatment in a complete, yet concise form. Based on
this comprehensive comparison, it goes on to discuss remaining open
questions and adjustments needed if the Directive is to be
implemented in national tax law. Readers seeking a basis for taking
an active part in the public debate will find a valuable source of
information and a first impression of how the proposed CC(C)TB
would affect corporate tax burdens in the European Union.
Die EU-Mitgliedstaaten haben sich das Ziel gesetzt, die
Aufwendungen fur Forschung und Entwicklung (FuE) bis zum Jahr 2010
auf 3% des Bruttoinlandsprodukts (BIP) anzuheben. Deutschland liegt
mit einem Anteil der FuE-Aufwendungen von 2,54% des BIP unter der
geforderten 3%-Marke. Zur Erreichung des Lissabon-Ziels fuhrt die
EU-Kommission eine steuerliche Breitenfoerderung von FuE als
wichtige Massnahme an. In Deutschland existieren im Gegensatz zur
Mehrzahl der EU-Mitgliedstaaten sowie zu bedeutsamen Drittstaaten
keine speziellen steuerlichen Massnahmen zur FuE-Foerderung. Die
Arbeitsgruppe Steuerliche FuE-Foerderung der Forschungsunion
Wirtschaft - Wissenschaft pruft in diesem Bericht, ob, inwieweit
und mittels welcher Instrumente auch in Deutschland eine direkte
steuerliche FuE-Foerderung in Erwagung gezogen werden kann. Als
Ergebnis werden konkrete Vorschlage zur Ausgestaltung einer
steuerlichen FuE-Foerderung in Deutschland entwickelt.
Preface This book contains the proceedings of the International Tax
Conference on the c- th th mon consolidated corporate tax base
(CCCTB) that was held in Berlin on 15 - 16 may 2007. The conference
was jointly organised by the German Federal Ministry of Finance,
the Centre for European Economic Research (ZEW), Mannheim, and the
Max Planck Institute (MPI) for Intellectual Property, Competition
and Tax Law, Munich. More than 250 participants from all over
Europe and other regions, scholars, politicians, business people
and tax administrators, discussed the Eu- pean Commission's
proposal to establish a CCCTB. Three panels of tax experts
evaluated the common tax base with respect to structural elements,
consolidation, allocation, international aspects and
administration. The conference made clear that the CCCTB has the
potential to overcome some of the most intriguing problems of
corporate income taxation within the Common Market. Common tax
accounting rules substantially reduce compliance and administrative
costs. Consolidation of a group's profits and losses effects cro-
border loss compensation which removes a major tax obstacle for
European cro- border investment. At the same time, tax planning
with respect to financing and transfer pricing is pushed back
within the European Union. Moreover, as far as the CCCTB applies,
member states are able to remove tax provisions that are targeted
at cross border tax evasion and that might be challenged by the
jurisdiction of the Eu- pean Court of Justice.
Our small book presents areport which has been prepared in the year
2000 for the Taxation and Custorns Union Directorate General of the
European Commission, under contract no. T AXUD / 00 / 312. Some of
the results form part of the report "Company Taxation in the
Internal Market" of the Commission Services released in autumn
2001. We present estimates of effective average tax rates (EATR) in
five EU Member States (France, Germany, Ireland, the Netherlands
and the UK) plus the USA based on the European Tax Analyzer
approach. The European Tax Analyzer is a computer based model firm
approach for the computation and comparison of international
company tax burdens. It has been developed in co-operation with the
Centre for European Economic Research (ZEW). We would like to thank
the ZEW for this co-operation. Furthermore, we gratefully
acknowledge the help and advice of Gerd Gutekunst, Rieo A. Hermann
and Thorsten Stetter in preparing the report. Special mention must
be made of Gerd Gutekunst, who was also responsible for preparing
the printed version of this report.
The European Commission envisages putting forward a proposal for a
tax reform that would allow improving the efficiency and simplicity
of the corporate income tax systems. This report assesses the
impact of a Common Corporate Tax Base (CCTB) on the size of the
corporate tax bases of EU companies. The results of the report
shall help to evaluate the economic consequences of the
introduction of a harmonised set of tax accounting rules. The
estimates are based on the European Tax Analyzer with data from the
year 2006 and apply options specified by the Commission 's Steering
Group.
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