Publisher's Synopsis
Also available as eBook.
The creation of a group taxation framework to subject affiliated
entities resident in more than one EC Member State to a single set of rules is
an experiment without precedent. Group taxation normally deals with tax
liability in the context of a single jurisdiction. There is no system of group
taxation worldwide which embraces more than one fiscal jurisdiction under a
single regulatory umbrella.
This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse.
Among the topics covered...
- The relevant jurisprudential and legislative framework of the European Internal Market;
- A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers;
- The policies for corporate taxation in integrated markets;
- Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability;
- Tests for entitlement to group membership;
- Tax base integration; - Territorial delineation of the group; and
- Formulary apportionment.
In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.
