Company Tax Reform in the European Union
Guidance from the United States and Canada on Implementing Formulary Apportionment in the EU
(Sprache: Englisch)
Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider...
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Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.
The European Commission presented a strategy that would allow EU companies to compute their EU tax base under a single set of tax rules at the EU level and use a common formula to distribute this tax base across the individual Member States.
Company Tax Reform and Formulary Apportionment in the European Union provides broad guidance for the EU in shaping a system of consolidated base taxation with formulary apportionment. It evaluates how the U.S. states and Canadian provinces have resolved the economic, political, and technical aspects of the formulary apportionment method.
The book discusses the landscape for company tax reform in the European Union and illustrates how formulary apportionment might distribute the tax base across the Member States. It provides practical information on how to design an apportionment formula and discusses selected compliance and administrative issues. It analyzes how formulary apportionment might affect investment, employment, tax revenues, and tax competition in the European Union.
Company Tax Reform and Formulary Apportionment in the European Union provides broad guidance for the EU in shaping a system of consolidated base taxation with formulary apportionment. It evaluates how the U.S. states and Canadian provinces have resolved the economic, political, and technical aspects of the formulary apportionment method.
The book discusses the landscape for company tax reform in the European Union and illustrates how formulary apportionment might distribute the tax base across the Member States. It provides practical information on how to design an apportionment formula and discusses selected compliance and administrative issues. It analyzes how formulary apportionment might affect investment, employment, tax revenues, and tax competition in the European Union.
Inhaltsverzeichnis zu „Company Tax Reform in the European Union “
- Preface- A New Direction in Company Taxation
- The Landscape for EU Company Tax Reform
- Formulary Apportionment and Consolidated Base Taxation
- The Apportionment Formula
- Nexus, the Income Tax Base and the Taxable Unit
- Tax Administration, Compliance and Tax Planning
- Economic Impacts of Formulary Apportionment
- Conclusion
Bibliographische Angaben
- Autor: Joann Martens-Weiner
- 2010, Softcover reprint of hardcover 1st ed. 2006, XVII, 122 Seiten, Maße: 15,5 x 23,5 cm, Kartoniert (TB), Englisch
- Verlag: Springer, Berlin
- ISBN-10: 1441939903
- ISBN-13: 9781441939906
Sprache:
Englisch
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