By Christoph Spengel (auth.), Professor Dr. Wolfgang Schön, Professor Dr. Ulrich Schreiber, Professor Dr. Christoph Spengel (eds.)
Preface This booklet includes the court cases of the overseas Tax convention at the c- th th mon consolidated company tax base (CCCTB) that used to be held in Berlin on 15 – sixteen may perhaps 2007. The convention was once together organised by means of the German Federal Ministry of Finance, the Centre for eu monetary learn (ZEW), Mannheim, and the Max Planck Institute (MPI) for highbrow estate, pageant and Tax legislation, Munich. greater than 250 members from far and wide Europe and different areas, students, politicians, enterprise humans and tax directors, mentioned the ecu- pean Commission’s inspiration to set up a CCCTB. 3 panels of tax specialists evaluated the typical tax base with recognize to structural parts, consolidation, allocation, foreign points and management. The convention made transparent that the CCCTB has the capability to beat probably the most fascinating difficulties of company source of revenue taxation in the universal industry. universal tax accounting principles considerably decrease compliance and administrative expenditures. Consolidation of a group’s gains and losses results cro- border loss reimbursement which gets rid of a tremendous tax challenge for ecu cro- border funding. even as, tax making plans with admire to financing and move pricing is driven again in the eu Union. additionally, so far as the CCCTB applies, member states may be able to eliminate tax provisions which are certain at go border tax evasion and that would be challenged via the jurisdiction of the ecu- pean court docket of Justice.
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Extra resources for A Common Consolidated Corporate Tax Base for Europe — Eine einheitliche Körperschaftsteuerbemessungsgrundlage für Europa
The first approach seems to be more consistent with the concept of consolidation and formula apportionment. Although the approach of consolidation is based on the notion that a group of companies forms an economic unit, under the concept of the CCCTB each of the group members remains liable to tax for its apportioned share of the consolidated tax base on an individual basis. The first approach leads to a symmetric treatment of profits and losses. Not only a positive but also a negative consolidated tax base is apportioned to each group member.
4. Implementation issues A CCCTB raises several implementation issues. 1 Determination of Taxable Income With regard to the determination of taxable income at the level of each group member different solutions seem to be possible. First, based on their factual importance, there could be a strict dependency of International Financial Reporting Standards (IFRS) for the determination of taxable income. However, there is no support to accept full dependency of IFRS. The evolution of IFRS is not yet clear, they include some accounting options which are not in line with fundamental and common principles of tax accounting (in particular fair-value accounting) and IFRS – like domes- 51 The implementation issues are addressed in more detail by Spengel/Wendt, A Common Consolidated Tax Base for Multinational Companies in the European Union.
Although the amount of real estate tax varies from country to country, real estate tax has no significant impact on the effective tax burden of companies, since the tax base is limited to only a few numbers of assets and tax rates are rather low. 15 16 See Jacobs, Intertax 1999, pp. 264-278, for a detailed analysis. See European Tax Handbook, Amsterdam 2007, and own investigations. 16 Christoph Spengel A property or net wealth tax on business assets of corporations is only imposed by Luxembourg.