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 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.

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.

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.

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.

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.