Corporate Income Taxation In Europe: The Common Consolidated Corporate Tax Base (CCCTB) and Third Countries

This topical book is the first publication that focuses on the impact of the CCCTB project on relations between the European Union and third countries. Although the CCCTB system will only be applicable within the European Union, it will also have wide-ranging impacts for non-resident companies.

Contents:

+ Preface

+ 1. Taxation of EU Resident Companies under the Current CCCTB Framework: Descriptive and Critical Approach to Selected ‘Extraterritorial’ Aspects
Edoardo Traversa and Charles-Albert Helleputte

++ Commentaries by Krister Andersson and Katharina Becker

+ 2. Taxation of EU-Non-Resident-Companies under the CCCTB System: Analysis and Suggestions for Improvement
Eric C.C.M Kemmeren and Daniël S. Smit

++ Commentary by Theo Keijzer

+ 3. The Meaning of ‘Resident Taxpayer’ and ‘Non-Resident Taxpayer’ under the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)
Guglielmo Maisto

+ 4. Withholding Taxation
Joachim Englisch

++ Commentary by Dennis Weber and Jan van de Streek

+ 5. CCCTB and Fiscally Transparent Entities: A Third Countries’ Perspective
Yariv Brauner

++ Commentary by Christian Kaeser

+ 6. Deductibility of Gifts to Charitable Bodies in Third Countries
Roman Seer

++ Commentary by Mitchell A. Kane

+ 7. Transfer of Assets to Third Countries
Daniel Gutmann

+ 8. The Limits to Interest Deductibility: An Ad Hoc Anti-abuse Rule in the Proposal for a CCCTB Directive
Pasquale Pistone

++ Commentary by Christoph Spengel

+ 9. CFC Rules Within the CCCTB
Christiana HJI Panayi

++ Commentaries by Walter Hellerstein and Richard Lyal

+ Index

• Primary Source