No description available.

The European Commission is currently working on a legislative draft to harmonise the corporate income tax provisions for multinational groups of companies throughout the European Union. For that purpose the European Commission has installed a working group with the mission to draft a Common Consolidated Corporate Tax Base (CCCTB) applicable for multinational companies. As the EU member states are not willing to surrender their taxing power to the supranational level of the EU each group entity's tax base would be determined by apportionment of the group's overall taxable income according to a predefined micro-economic factor based formula whereas the group income will be calculated by consolidating earnings beforehand separately determined by each group entity (preconsolidation income). The situs state of the particular group entity would then apply its statutory corporate tax rate on the apportioned tax base. This paper evaluates the effects of this prospective apportionment procedure on any given corporate group entity and finds that the share of the group's income allocated to a particular entity using the apportionment formula does regularly not equal the pre-consolidation income of the respective group entity. The reasons for this regular observable deviation can be found on the one hand in the concept of the apportionment formula and on the other hand in the specifics of the definitions of the apportionment factors. (author's abstract) / Series: Discussion Papers SFB International Tax Coordination

A major goal of the EU Commission in the area of direct taxation is the introduction of a common consolidated corporate tax base (CCCTB) in Europe. While hardly discussed in the literature, such a system would limit national discretion over tax depreciation. In a sample of up to 47 countries, we find that the probability of a tax reform that improves the depreciation allowances increases, if the macroeconomic situation is weak. This suggests that changes in depreciation allowances are used as a fiscal instrument for stabilization. A common consolidated tax base deprives national governments from implementing investment incentives via accelerated depreciation. This paper discusses the possible implementation of a hybrid system that combines features of formula apportionment and separate accounting. Such a hybrid system may substantially mitigate transfer pricing problems and other tax planning issues, whilst preserving national discretion over depreciation allowances. / Series: WU International Taxation Research Paper Series

This paper is focus on deductible costs in the project CCCTB. I describe and compare, from the perspective of tax deductible expenses, tax legislation in selected countries of the European Union. I suggest a possible way how this costs should be defined and treated as a tax deductible for the tax agency in the project Common Consolidated Corporate Tax Base.

In March 2011, the European Commission submitted a proposal for a Council Directive on an optional common consolidated corporate tax base (CCCTB). If this proposed CCCTB system comes into force, taxes calculated under the currently existing system of separate accounting might be replaced by a system of group consolidation and formulary apportionment. Then, multinational groups (MNGs) would face the decision as to whether to opt for the CCCTB system. Prior research focuses mainly on the differences in economic behaviour under both systems in general. By contrast, we study the conditions under which one or the other tax system is preferable from the perspective of an MNG, with a particular focus on loss-offsets. We identify four effects that determine the decision of an MNG: the tax-utilization of losses, the allocation of the tax base, the dividend and intragroup interest taxation. We find mixed results, e.g., that the CCCTB system proves advantageous for increasing loss/profit streams (e.g. from start-ups or R&D projects) of the individual group entities, whereas the system of separate accounting is beneficial for decreasing profit/loss streams (e.g. caused by a decrease in return from a mature product). The results of our analysis are helpful for MNGs facing the decision as to whether to opt for the CCCTB system and can also support legislators and politicians in the EU but also in other regions in their tax reform discussions. (authors' abstract)

The diploma thesis deals with taxation of the digital business in European union. The Common Consolidated Corporate Tax Base (CCCTB) has been chosen to quantify the impacts of the taxation of the digital business. The research was conducted in two steps. In the first step, a three-factor allocation equation is used to quantify impacts. In the second step, the allocation equation is extended by a digital factor. The identification of the impacts of the CCCTB implementation is based on a comparison of the current situation of the distribution of the tax base with the newly created distribution after the implementation of the allocation equations. Subsequently, the current tax revenue of each Member State is compared with tax revenue following the implementation of the CCCTB system. Although the thesis identified a decrease in the total tax base in the CCCTB system, the overall tax revenue of the member states was higher for both allocation equations compared to the current situation. The introduction of a digital factor results in increased total tax revenues for the European Union as a whole.

As a result of a growing number of Member States of the European Union the idea of unification and co-ordination of legal changes,including tax systems of each country, is growing stronger. The common consolidated corporate tax base (CCCTB) should establish unified rules for determining the tax base, and consequently this would eliminate double taxation, cross-border income, or tax evasion and suppression of tax competition among the states of the European Union. This work deals with the redistributive mechanism of the CCCTB, which would alocate the CCCTB to the group of the individual companies. Interim result of the discussion is to create a distribution threefactors formula consisting of variables - work, asset and sales. I applied the current conclusions of the European Commission to the Czech company Skoda Auto,a.s., whose parent company is in Germany.

No description available.

The theme of this dissertation thesis is: The perspectives of harmonization of direct income taxes in the European Union. The reason for choosing this topic was firstly the current issue, which offers a wide scope for research and polemic over new approaches and solutions in the European and international tax law. The European Union is a supranational organization founded on the principle of conferral of powers. The ideas of the approximation of the laws are not only its own, but occur throughout the world community, because thanks to the harmonization of certain legislation the benefits of international trade can maximize. The idea of exclusion from economic cooperation today is practically unrealistic. In the European Union the harmonization of laws is directly related to the development of the internal market. The European Union has a long-term goal to create a market that acts as a market of one country. The instrument of harmonization seeks to eliminate differences in legal systems so as not to impede the implementation of the four fundamental freedoms of the internal market. Taxation is a very specific and also sensitive area. The area of taxation is traditionally perceived as a sovereign expression of state sovereignty. The aim of this thesis is the attempt to find the best solutions how to...

The European Commission on 16 March 2011 proposed a harmonized system for the tax base calculation of companies operating in the EU. The proposed Common Consolidated Corporate Tax Base (CCCTB) indicates that businesses would benefit from a "one-stop-shop" system for filing their tax returns and would be able to consolidate all the profits and losses they incur across the EU. Member States would maintain their full sovereign right to set their own corporate tax rate. However, many Member States are against this new system as they think that CCCTB does not meet principles of subsidiarity and proportionality and is not available to reach its goals. Therefore, the hypothesis of this Master Thesis was formulated that CCCTB is an appropriate way to reach company tax harmonization in the EU and abolish obstacles which arise because of 27 different taxation systems in EU. After comprehensive analysis of major company taxation obstacles in the first chapter, these main barriers were identified: double taxation, additional compliance cost, over-taxation which arise in cross-border activities. The main measures such as Parent-Subsidiary Directive, Merger Directive, Interest and Royalties Directive and Arbitration Convention designed to cope with these barriers were discussed and the main challenges needed to solve by CCCTB were formulated. Proposed Directive and main elements of CCCTB were investigated in the second chapter. As there is a disagreement between Member States regarding to... [to full text] / Europos Komisija 2011 m. kovo 16 d. pateikė pasiūlymą harmonizuoti pelno mokesčio bazės apskaičiavimą. Pasiūlyta Bendra konsoliduota pelno mokesčio bazė (BKPMB) reiškia, kad būtų taikomas „vieno langelio” principas pildant vieną deklaraciją ir įmonės galėtų konsoliduoti visą pelną ir nuostolius pagal bendras taisykles. Valstybės išlaikytų nepriklausomą teisę nustatyti apmokestinimo tarifus. Tačiau dauguma ES valstybių yra prieš šios sistemos įvedimą, jos savo prieštaravimus grindžia tuo, kad BKPMB pažeidžia subsidiarumo ir proporcingumo principus bei nėra pajėgi pasiekti savo tikslų. Dėl to buvo šiame darbe buvo iškelta hipotezė: BKPMB yra tinkamas būdas siekti įmonių apmokestinimo harmonizavimo ir panaikinti kliūtis, kurios kyla taikant 27 skirtingas apmokestinimo sistemas ES. Atlikus išsamią analizę pirmojoje dalyje šios pagrindinės kliūtys buvo nustatytos: dvigubas apmokestinimas, didelės mokestinių reikalavimų laikymosi sąnaudos bei tarpvalstybinės nuostolių užskaitos apribojimas. Taip pat buvo nagrinėjami pagrindiniai dokumentai: Direktyva dėl bendrosios mokesčių sistemos, taikomos įvairių valstybių narių patronuojančioms ir dukterinėms bendrovėms; Direktyva dėl bendros mokesčių sistemos, taikomos įvairių valstybių narių įmonių jungimui, skaidymui, turto perleidimui ir keitimuisi akcijomis; Direktyva dėl bendros apmokestinimo sistemos, taikomos palūkanų ir autorinių atlyginimų mokėjimams tarp skirtingų valstybių narių asocijuotų bendrovių; Konvencija dėl dvigubo... [toliau žr. visą tekstą]