Corporate Income Taxation In Europe - The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries

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. The book considers the impact of the CCCTB from the perspective of non-EU-based enterprises that are carrying on business in the EU through the operation of branches or subsidiaries in member states. It incorporates the perspectives of leading scholars from all over Europe as well as from third countries such as the United States, and provides in-depth analysis of the key aspects which would affect third countries, such as: withholding taxation, taxation of transparent entities, and transfer of assets to third countries. Corporate Income Taxation in Europe will provide essential insights to academics, practitioners and policymakers in the field of taxation. It will also interest those looking ahead to future tax reforms in the EU, or considering how a similar model may be applied elsewhere.

Contents: Preface 1. Taxation of EU Resident Companies under the Current CCCTB Framework: Descriptive and Critical Approach to Selected ‘Extraterritorial’ Aspects Edoardo Traversa and Charles-Albert Helleputte Commentaries by Krister Andersson and Katharina Becker 2. Taxation of EU-Non-Resident-Companies under the CCCTB System: Analysis and Suggestions for Improvement Eric C.C.M Kemmeren and Daniël S. Smit Commentary by Theo Keijzer 3. The Meaning of ‘Resident Taxpayer’ and ‘Non-Resident Taxpayer’ under the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB) Guglielmo Maisto 4. Withholding Taxation Joachim Englisch Commentary by Dennis Weber and Jan van de Streek 5. CCCTB and Fiscally Transparent Entities: A Third Countries’ Perspective Yariv Brauner Commentary by Christian Kaeser 6. Deductibility of Gifts to Charitable Bodies in Third Countries Roman Seer Commentary by Mitchell A. Kane 7. Transfer of Assets to Third Countries Daniel Gutmann 8. The Limits to Interest Deductibility: An Ad Hoc Anti-abuse Rule in the Proposal for a CCCTB Directive Pasquale Pistone Commentary by Christoph Spengel 9. CFC Rules Within the CCCTB Christiana HJI Panayi Commentaries by Walter Hellerstein and Richard Lyal Index