Corporate Income Taxation in Europe
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Corporate Income Taxation in Europe

The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries

Edited by Michael Lang, Pasquale Pistone, Josef Schuch, Claus Staringer and Alfred Storck

This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies.
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Krister Andersson


Obstacles to cross-border business transactions deriving from corporate taxation are a real problem and cause significant costs for promoting growth and employment. The lack of cross-border loss relief constitutes a major obstacle to achieving a functioning Single Market. The large number of disputes in the transfer pricing area is another example of tax obstacles to an efficient Single Market. The proposed directive on a Common Consolidated Corporate Tax Base could provide a lasting solution to these problems at least between participating countries, thus making it very important to businesses engaging in cross-border activities. The question of how to find a constructive way to split the tax cake is long overdue. There is an on-going debate about corporate tax payments and their allocation across countries and regions. In these discussions it is crucial to uphold the principle of single taxation, not international double taxation. The slices must not exceed the size of the cake. How to split the tax cake should be a contest between governments – not between a company or a group of companies and the government of a country. The authors make an interesting historical exposé running from the Neumark and Ruding reports to the present CCCTB Directive proposal. They also give a good summary of the many features contained in the proposal. Their chapter deals with the extraterritorial aspects of the CCCTB.

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