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As a result of the progress in information and communication technologies (ICT) economic activities have become less dependent on time and place. This is leading to manifold changes in economic structures. Consequently, the question is whether and to what extent the existing rules of international company taxation are still applicable in an appropriate way. Anne Schäfer analyses the current issues of international company taxation with regard to the economic changes induced by the use of ICT and provides reform approaches for international company taxation which cover the whole system of international taxation. She presents proposals for the reform of the definition of a company's residence, the definition of the permanent establishment, the possibilities of profit allocation and the methods to avoid international double taxation. In addition, the interrelations between these issues are taken into account. Amongst others, the author argues for an extension of the definition of a permanent establishment for employees working permanently abroad and for an implementation of formula apportionment in the European Union.

Tax law --- internationaal recht --- fiscaal recht

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In 2004, the first legal entity applicable in all EU member states, the so-called European Company or Societas Europaea (SE), was introduced. Especially, the taxation of hidden reserves is still a major concern for companies wanting to reorganize themselves across borders. Christiane Malke analyzes the current issues resulting from the entry into an SE, the transfer of seat of an SE from one EU member state to another one and the exit out of an SE in the 27 member states of the EU taking into consideration the Merger Directive. Based on existing deficiencies the author provides reform approaches that consider changes to the national law of the member states, to EU law as well as to the proposals provided by the European Commission regarding the introduction of a Common (Consolidated) Corporate Tax Base.

Taxes --- Tax law --- financieel management --- fiscaal recht --- accountancy

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Even though multinational companies doing business across the European Union generally operate at the EU level, they must still compute a separate company tax base for each Member State where they do business. This process creates enormous compliance burdens as integrated multinational enterprises struggle to find appropriate "arm's length" prices for their internal transfers of goods, services and intangibles. This process fails to tax EU companies in a manner consistent with how they do business in the European Union. By contrast to this system of separate acounting with arm's length pricing, consolidated base taxation with formulary apportionment is an ideal system to apply to tax multinational enterprises in the European Union. Company Tax Reform in the European Union. Guidance from the United States and Canada on Implementing Formulary Apportionment in the EU draws from experiences in the U.S. states and Canadian provinces to provide guidance to the European Union. The book describes the new landscape for company tax reform in the EU and how formulary apportionment fits into that landscape. It discusses practical issues concerning the fundamental elements of a formulary apportionment system and evaluates technical issues concerning how formulary apportionment may affect investment, employment, tax planning, and tax competition in the European Union. The book emphasizes that formulary apportionment preserves EU Member State tax sovereignty and allows them to remain competitive in the drive to stimulate new investment and employment. "Dr. Martens-Weiner's book draws on the U.S. and Canadian experience in using formulary apportionment to achieve a reasonable allocation of income across fiscal borders. The lessons she draws should inform the EU debate over formulary apportionment." Emil M. Sunley, Assistant Director Fiscal Affairs Department, International Monetary Fund "Company Tax Reform in the European Union gave me new insights on the U.S. and Canadian experiences with formulary allocation of business income. Reading it will be a must for anybody who wants to take part in the forthcoming discussion of the future common consolidated corporate tax base and its formula allocation to different EU Member States." Dr. Albert J. Rädler Prof. em. of International Business Taxation, International Tax Institute, University of Hamburg Senior Tax Partner, Linklaters Oppenhoff & Rädler, Munich office Member of the Ruding Committee, Brussels 1991/1992 "An important volume that will prove valuable as the European Union decides whether -- and how -- to harmonize company income taxes." Charles E. McLure, Jr. Hoover Institution, Stanford University "This book is important reading for both tax policymakers and business leaders. It breaks the mold of conventional thinking by demonstrating that formulary apportionment is a practical way to solve the income-allocation problems confronting the European Union. Equally important, the book gives the advocates of arm's-length allocation methods some challenging food for thought." Thomas F. Field Founder, Tax Analysts Joann Martens-Weiner is a renowned world expert on formulary apportionment. She has dedicated more than 15 years to the subject, beginning with her dissertation on the economic effects of the formulary apportionment system used in the United States and Canada. Dr. Martens-Weiner has a Ph.D. in economics from Harvard University and a B.S. in Business Administration from the University of California at Berkeley. She has served as an economist in the Office of Tax Analysis at the U.S. Treasury Department and as an expert on formulary apportionment for the Directorate-General for Taxation and Customs Union at the European Commission.

Public finance --- Public economics --- Economics --- Tax law --- economie --- fiscaal recht --- overheidsfinanciën --- Canada

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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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Managerial decisions are considerably influenced by taxes: e.g. the choice of location, buying or leasing decisions, or the proper mix of debt and equity in the company's capital structure increasingly demand qualified employees in an economic environment that is becoming more and more complex. Due to the worldwide economic integration and constant changes in tax legislation, companies are faced with new challenges - and the need for information and advice is growing accordingly. This book's goal is to identify and quantify possible tax effects on companies' investment strategies and financing policies. It does not focus on details of tax law, but instead seeks to address students and practitioners focusing on corporate finance, accounting, investment banking and strategy consulting.

Finance --- Economic policy and planning (general) --- Economics --- Tax law --- Audit --- Accountancy --- boekhouden --- economie --- economische politiek --- financiën --- fiscaal recht --- auditing