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"Preface" [2013] ELECD 1146; in Lang, Michael; Pistone, Pasquale; Schuch, Josef; Staringer, Claus; Storck, Alfred (eds), "Corporate Income Taxation in Europe" (Edward Elgar Publishing, 2013) xii

Book Title: Corporate Income Taxation in Europe

Editor(s): Lang, Michael; Pistone, Pasquale; Schuch, Josef; Staringer, Claus; Storck, Alfred

Publisher: Edward Elgar Publishing

ISBN (hard cover): 9781782545415

Section Title: Preface

Number of pages: 3

Extract:

Preface
The European Commission is considering a fundamental change to the
tax system for companies with taxable operations in the European Union.
The new system is called the Common Consolidated Corporate Tax Base
(CCCTB). Companies that are eligible for and opt in to the CCCTB
would be taxed on their consolidated taxable profits across the participat-
ing Member States. Those profits would be allocated between the
participating Member States based on a formula apportionment and taxed
in each of the states at the corporate tax rate applicable in that state. This
would replace the existing system where each Member State, based on its
own rules, taxes the profits of companies with a taxable nexus in that
country.
Given that a significant European investment comes from third coun-
tries, the CCCTB regulations and their relationship to those third
countries require more analysis and careful thought. So far, not much
thought has been given to how the CCCTB affects companies based
outside Europe. Accordingly, the main purpose of this book was to fill
this gap and to take the first steps toward research in that field. In a total
of nine chapters, issues such as the taxation of EU and EU non-resident
companies are dealt with. Great attention is also given to the issues of
withholding taxation and the deductibility of expenses. Questions regard-
ing the transfer of assets to third countries or the treatment of transparent
entities are also of high importance.
This project was carried out by an international ...


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