Taxation of European Companies during the time of restructuring in an ideal environment
As has been pointed out above, a Societas Europaea may not be established by individuals via a contribution of cash or assets but solely by reorganization of entities already existing. Furthermore, a feature of the SE is the possibility to transfer the registered office from one country to another without losing the legal entity. Thus, in the following, the focus is on generally accepted principles which need to be observed in such transactions from a tax perspective. In this chapter an ideal environment is considered. An ideal environment may be defined as an area with a uniform tax system in which the transaction takes place, thus an area without borders. Such an environment would be provided if the transaction occurs within one country. Taking the aim of the European Company Statute into consideration, it should also be provided within the internal market of the European Union.
KeywordsLegal Form Ideal Environment Historical Cost Reorganization Process Realization Principle
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