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The taxation of multinational corporate groups has become a major concern in the academic and political debate on the future of international taxation. In particular the arm's length standard for the determination of transfer prices is under increasing pressure. Many countries and international bodies are now taking a closer look at the use of transfer prices for profit shifting and are exploring alternative mechanisms such as formulary apportionment for the allocation of taxing rights. With regard to this topic, this volume is the first to offer a concise analysis of transfer pricing in the international tax arena from an interdisciplinary legal and economic point of view. Fundamentals such as the efficient allocation of resources within multi-unit firms and distortions between different goals of transfer pricing as well as different aspects of it in tax and corporate law, the traditional OECD approach and practical aspects concerning intangibles, capital and risk allocation are covered by outstanding authors.
Public finance --- Public economics --- Commercial law --- Commercial law. Economic law (general) --- handelsrecht --- economisch recht --- internationaal recht --- overheidsfinanciën --- Prix de cession interne --- Droit commercial (droit international) --- Finances publiques --- Impôts --- Droit
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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.
financieel recht --- Tax law --- Europees recht --- European law --- Europese eenmaking --- fiscaal recht --- Financial law --- Europe --- Business tax --- Law and legislation
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The interaction of tax and corporate governance forms an emerging issue both in business and administrative practice and in academic research. International organisations (OECD, EC) have begun to explore the effects corporate governance rules exert on the tax policy of large business; governments try to employ corporate and securities law as a means to further their fiscal interest. Academic research shows that well-known principal-agent and capital market problems are strongly influenced by tax considerations. Against this background, this volume is the first to present a fully-fledged overview of the interdependence of tax and corporate governance. Not only the basic political, legal and economic questions but also major topics like income measurement, shareholding structures, corporate social responsibility and tax shelter disclosure are covered extensively by leading authors.
Corporations --- Corporate governance --- Taxation --- Law and legislation --- Governance, Corporate --- Industrial management --- Directors of corporations --- Business corporations --- C corporations --- Corporations, Business --- Corporations, Public --- Limited companies --- Publicly held corporations --- Publicly traded corporations --- Public limited companies --- Stock corporations --- Subchapter C corporations --- Business enterprises --- Corporate power --- Disincorporation --- Stocks --- Trusts, Industrial --- Tax accounting. --- Business Taxation/Tax Law. --- International Economic Law, Trade Law. --- Private International Law, International & Foreign Law, Comparative Law . --- Finance, Public --- Accounting --- corporate governance --- impot des societes --- 336.01 --- 336.214 --- 658.40 --- AA / International- internationaal --- financieel beheer ondernemingen --- vennootschapsbelasting --- Overheidsbemoeiing op economisch gebied --- Belastingstelsel van de genootschappen --- Financieel beheer van de bedrijven: algemeenheden --- gestion financiere des entreprises --- Tax laws. --- International law. --- Trade. --- Private international law. --- Conflict of laws. --- Choice of law --- Conflict of laws --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Law of nations --- Nations, Law of --- Public international law --- Tax laws --- Tax legislation --- Tax regulations --- Civil law --- Business tax --- Trade regulation. --- Comparative law. --- Business Taxation and Tax Law. --- Private International Law, International and Foreign Law, Comparative Law. --- Taxation. --- Law and legislation. --- Comparative jurisprudence --- Comparative legislation --- Jurisprudence, Comparative --- Law, Comparative --- Legislation, Comparative --- Regulation of trade --- Regulatory reform --- Trade regulation --- Commercial law --- Consumer protection --- Deregulation
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