Add to ORKGThis thesis analyses whether there is a necessity to have two different CFC regimes in two legislations, the ATAD and the CCTB proposal. The author examines the issues that are already present in the CFC that pose problems. This could support the argument that the EC’s actions in the implementation of the ATAD and the CCTB have been over-reaching in the EC’s attempt to eradicate tax erosion and profit shifting through the examination of the CFC provisions in the ATAD and the CCTB proposal. In this context, this article focuses on the analysis of Articles 7-8 of the ATAD and Articles 59-60 of CCTB
In this article the proposal Concerning \u201cBest Practices\u201d and Principles for a Common Legis...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
The CFC & FIF regimes were originally enacted to prevent New Zealand taxpayers using tax havens to a...
This thesis analyses whether there is a necessity to have two different CFC regimes in two legislati...
peer reviewedThis short chapter analyses the relationship between the interest limitation rules laid...
Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which ...
The subject of the article is to present the OECD’s recommendations issued within the Base Erosion a...
Although direct taxation falls under the sovereignty of each individual Member State, that sovereign...
Unlike other previous EU Directives in the field of direct taxation, the Anti-Tax Avoidance Directiv...
This Article examines the European Commission\u27s Home State Taxation and CCCTB initiatives. It arg...
In 2016, the European Commission re-launched the project for a common consolidated corporate tax bas...
peer reviewedThe Controlled Foreign Company (CFC) regime proposed by the Commission as part of the n...
This article demonstrates that after the seemingly incorrect implementation of Articles 7–8 of the A...
Since its conception, some within the European Union have expressed concerns over the ability of mu...
Most states within the EU have some kind of CFC-legislation that allows the state in question to tax...
In this article the proposal Concerning \u201cBest Practices\u201d and Principles for a Common Legis...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
The CFC & FIF regimes were originally enacted to prevent New Zealand taxpayers using tax havens to a...
This thesis analyses whether there is a necessity to have two different CFC regimes in two legislati...
peer reviewedThis short chapter analyses the relationship between the interest limitation rules laid...
Generally, the ALP in TP regulations is widely applied in order to prevent price manipulation which ...
The subject of the article is to present the OECD’s recommendations issued within the Base Erosion a...
Although direct taxation falls under the sovereignty of each individual Member State, that sovereign...
Unlike other previous EU Directives in the field of direct taxation, the Anti-Tax Avoidance Directiv...
This Article examines the European Commission\u27s Home State Taxation and CCCTB initiatives. It arg...
In 2016, the European Commission re-launched the project for a common consolidated corporate tax bas...
peer reviewedThe Controlled Foreign Company (CFC) regime proposed by the Commission as part of the n...
This article demonstrates that after the seemingly incorrect implementation of Articles 7–8 of the A...
Since its conception, some within the European Union have expressed concerns over the ability of mu...
Most states within the EU have some kind of CFC-legislation that allows the state in question to tax...
In this article the proposal Concerning \u201cBest Practices\u201d and Principles for a Common Legis...
The primary aim of this article is to question whether the general anti-abuse rule (GAAR) of Anti-Ta...
The CFC & FIF regimes were originally enacted to prevent New Zealand taxpayers using tax havens to a...