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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Walter Hellerstein


The following comments on the proposed CCCTB CFC rules are written from the perspective of a third-country observer who has focused largely on the text of the CFC rules and who professes no familiarity with either their extensive “legislative history” or the European Court of Justice case law that may affect them. Such a limitation on any remarks could be regarded as an interesting “thought experiment” designed to tease out the implications of the plain meaning of the language of the CCCTB CFC rules uninfluenced by “extra-textual” sources. In my case, however, the introductory caveat is more accurately viewed as “truth in advertising”, because of my general lack of familiarity with the details of the CCCTB, its legislative history and the relevant EU case law.126 The restriction on the scope of my comments thus relieves me of the burden of undertaking any inquiry into the thorny questions of how the CFC rules are to be construed with respect to non-CCCTB Member State companies – questions that are better left to others with an intimate understanding of the intra-EU issues raised by the CFC and related rules. Instead, I shall focus my attention exclusively on the application of the CCCTB CFC rules as written to corporations resident in third countries.

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