Dennis Weber – författare

This book showcases the practical insights of some of Europe’s foremost tax advisers and lawyers on recent case law issuing from the European Court of Justice. It also provides readers with informed analysis on how the Court may rule on future controversies impacting direct taxation.

This timely and useful resource will examine each of the following topics, inter alia:

• CFC Legislation and Abuse of Law in the Community

• Free movement of capital and non-member countries – consequences for direct taxation

• Striking a proper balance between the national fiscal interests and the Community interest – a perpetual struggle?

• Personal income taxation of non-residents and the increasing impact of the EC Treaty Freedoms

• Why the European Court of Justice should interpret directly applicable Community law as a right to most-favoured nation treatment and a prohibition of double taxation

• Fiscal Cohesion, Fiscal Territoriality, and Preservation of the (Balanced) Allocation of Taxing Power; What is the Difference?

• Limitation of the Temporal Effects of Judgments of the ECJ

• Tax Facilities for State-induced Costs under the State Aid Rules

• EU Law and rules of tax procedure

In October 2016, the European Commission relaunched its plan to harmonize national income tax systems via the Common Consolidated Corporate Tax Base (CCCTB), perhaps the most ambitious reform of EU tax law ever attempted. This timely book offers an early analysis of this important proposal and its implications, covering issues such as the project’s scope and main elements, international considerations, the relationship with OECD’s base erosion and profit shifting (BEPS) initiative, consolidation, and anti-abuse rules.

With carefully selected papers first presented at a January 2017 conference hosted by the Amsterdam Centre for Tax Law, this volume focuses on such topics and issues as the following:

Because of the commitment of many Member States to keep their corporate income tax systems competitive on a stand-alone basis, the proposed CCCTB is enormously controversial. This book provides authoritative insights into problems likely to arise and discusses the prospects of how the proposal is likely to be implemented. Thus, this book proves to be of immeasurable value to taxation policymakers, practitioners, and academics.

In October 2016, the European Commission relaunched its plan to harmonize national income tax systems via the Common Consolidated Corporate Tax Base (CCCTB), perhaps the most ambitious reform of EU tax law ever attempted. This timely book offers an early analysis of this important proposal and its implications, covering issues such as the project’s scope and main elements, international considerations, the relationship with OECD’s base erosion and profit shifting (BEPS) initiative, consolidation, and anti-abuse rules.

With carefully selected papers first presented at a January 2017 conference hosted by the Amsterdam Centre for Tax Law, this volume focuses on such topics and issues as the following:

Because of the commitment of many Member States to keep their corporate income tax systems competitive on a stand-alone basis, the proposed CCCTB is enormously controversial. This book provides authoritative insights into problems likely to arise and discusses the prospects of how the proposal is likely to be implemented. Thus, this book proves to be of immeasurable value to taxation policymakers, practitioners, and academics.

Although still under development, Pillar 2 of the OECD Global Anti-Base Erosion Model Rules is already posing significant challenges for taxation authorities worldwide. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in the field of corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries. This book provides the first in-depth survey of the implications of the Rules for all stakeholders, with detailed annotations by nineteen renowned experts in the field of multinational corporate taxation who describe the relevant provisions with examples and considerations addressing their scope, functioning, and interaction.

Undergirded by a comprehensive discussion of the Rules, their technical operation, and the administrative guidance provided by OECD, topics covered include the following:

definitions of tax terms for Pillar 2 purposes;

computation of income or loss, adjusted covered taxes, effective tax rate, and top-up tax;

jurisdictional blending and loss offsets;

effect of corporate restructurings and holding structures;

excluded categories of income;

carve-out opportunities under the Substance-Based Income Exclusion (SBIE);

transitional country-by-country and time-limited safe harbours; and

differences and interactions between the OECD Global Anti-Base Erosion (GloBE) and both the EU Pillar 2 Directive and the US Global Intangible Low-Taxed Income (GILTI) regimes.

It has been estimated that the GloBE reform would produce a worldwide additional tax revenue of USD 200 billion annually. It has thus become imperative for taxation authorities, tax practitioners, and multinational corporate counsel to become as aware as possible of the intricacies of the Pillar 2 Rules, and for this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.

Although still under development, Pillar 2 of the OECD Global Anti-Base Erosion Model Rules is already posing significant challenges for taxation authorities worldwide. Intended to establish a floor in the possibilities for countries to compete for corporate investment with each other in the field of corporate income taxation, the Pillar 2 Rules arising from the OECD/G20 Inclusive Framework have been agreed on by 140 countries. This book provides the first in-depth survey of the implications of the Rules for all stakeholders, with detailed annotations by nineteen renowned experts in the field of multinational corporate taxation who describe the relevant provisions with examples and considerations addressing their scope, functioning, and interaction.

Undergirded by a comprehensive discussion of the Rules, their technical operation, and the administrative guidance provided by OECD, topics covered include the following:

definitions of tax terms for Pillar 2 purposes;

computation of income or loss, adjusted covered taxes, effective tax rate, and top-up tax;

jurisdictional blending and loss offsets;

effect of corporate restructurings and holding structures;

excluded categories of income;

carve-out opportunities under the Substance-Based Income Exclusion (SBIE);

transitional country-by-country and time-limited safe harbours; and

differences and interactions between the OECD Global Anti-Base Erosion (GloBE) and both the EU Pillar 2 Directive and the US Global Intangible Low-Taxed Income (GILTI) regimes.

It has been estimated that the GloBE reform would produce a worldwide additional tax revenue of USD 200 billion annually. It has thus become imperative for taxation authorities, tax practitioners, and multinational corporate counsel to become as aware as possible of the intricacies of the Pillar 2 Rules, and for this reason, this detailed discussion and analysis will be greatly appreciated by taxation professionals worldwide.