Taxation of Foreign Business Income Within the European Internal Market

Taxation of Foreign Business Income Within the European Internal Market
Author :
Publisher : IBFD
Total Pages : 415
Release :
ISBN-10 : 9789087221133
ISBN-13 : 9087221134
Rating : 4/5 (134 Downloads)

Book Synopsis Taxation of Foreign Business Income Within the European Internal Market by : Jérôme Monsenego

Download or read book Taxation of Foreign Business Income Within the European Internal Market written by Jérôme Monsenego and published by IBFD. This book was released on 2012 with total page 415 pages. Available in PDF, EPUB and Kindle. Book excerpt: The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriality or on the principle of worldwide taxation, are in conflict with the objective of achievement of the internal market. This objective is indeed difficult to reach when it comes to the taxation of foreign income, given that the Member States are far from taxing companies doing business cross-border as if their operations were purely domestic. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation and the attribution of profits to permanent establishments. This dissertation analyses this conflict on the basis of a study of the case law of the European Court of Justice as well as some of the key provisions of the European treaties. It appears that both the fiscal principle of territoriality and the principle of worldwide taxation give rise to complex issues of compatibility with the law of the European Union. Although the analysis conducted throughout the dissertation provides some guidance for the taxation of the foreign business income of companies, it is concluded that the Court cannot, by itself, efficiently resolve the conflict between such taxation and the objective of achievement of the internal market.


Taxation of Foreign Business Income Within the European Internal Market Related Books

Taxation of Foreign Business Income Within the European Internal Market
Language: en
Pages: 415
Authors: Jérôme Monsenego
Categories: Business enterprises, Foreign
Type: BOOK - Published: 2012 - Publisher: IBFD

GET EBOOK

The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriali
Harmful Tax Competition
Language: en
Pages: 92
Authors: Organisation for Economic Co-operation and Development. Committee on Fiscal Affairs
Categories: Business & Economics
Type: BOOK - Published: 1998 - Publisher: Organisation for Economic Co-operation and Development

GET EBOOK

Globalisation has had positive effects on the development of tax systems and has encouraged countries to engage in base broadening and rate reducing tax reforms
CJEU Case Law in Direct Taxation: Territoriality and Fundamental Freedoms
Language: en
Pages: 253
Authors: Stephanie Zolles
Categories: Law
Type: BOOK - Published: 2023-07-13 - Publisher: Linde Verlag GmbH

GET EBOOK

The principle of territoriality and the fundamental freedoms The tension between the fundamental freedoms and the sovereignty of the Member States is omnipresen
Allocating Taxing Powers within the European Union
Language: en
Pages: 232
Authors: Isabelle Richelle
Categories: Law
Type: BOOK - Published: 2013-03-14 - Publisher: Springer Science & Business Media

GET EBOOK

The contributions to this volume try to overcome the traditional approach of the judicature of the European Court of Justice regarding the application of the fu
Research Handbook on European Union Taxation Law
Language: en
Pages: 663
Authors: Christiana HJI Panayi
Categories: Law
Type: BOOK - Published: 2020-01-31 - Publisher: Edward Elgar Publishing

GET EBOOK

Offering a comprehensive exploration of EU taxation law, this engaging Research Handbook investigates the associated legal principles in the context of both dir