Taxation of European Companies during the time of restructuring in the current environment
When examining the rules currently applicable to the SE upon establishment and transfer of the registered office in EU member states, not only one tax system is affected but at least two treasuries are involved. Such restructuring operations involving companies from different countries may not only raise legal and psychological difficulties but also significant tax issues. The following sections will examine how the guidelines established in Chapter 3 need to be adapted in such an environment (Section 4.1). Then, the currently applicable rules are described and compared (Section 4.2). Finally the rules are critically analyzed and - based on these findings - reform options are proposed (Section 4.3).
KeywordsMember State Capital Gain International Financial Reporting Standard Fair Market Double Taxation
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