Taxation of European Companies during the time of restructuring in the proposed environment
As has been pointed out above, the focus of the ongoing work at the level of the European Commission is on introducing a Common (Consolidated) Corporate Tax Base throughout Europe, as this is regarded to be a systematic way for companies to overcome the tax obstacles in the internal market and an acceptable way for member states to come to an agreement. Despite the option to not change the current system (“no change” scenario), the European Commission distinguishes between the concept of a Common Corporate Tax Base and the concept of a Common Consolidated Corporate Tax Base. In the following analysis the emphasis is placed on aspects which specifically concern reorganization and transfer processes. The examination is based on the work carried out by the working groups established by the European Commission. A critical discussion of the proposed change in the tax system in general is beyond the subject of this thesis. Before explaining and examining the proposed concepts from the perspective of reorganization and transfer processes, the relevant guidelines from this perspective will be assessed.
KeywordsMember State Commission Service Fair Market Permanent Establishment Apportionment Formula
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