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The Resource Compensation of losses in foreign subsidiaries within the EU : a comparative study of the unilateral loss-compensation mechanisms in Austria and Denmark

Compensation of losses in foreign subsidiaries within the EU : a comparative study of the unilateral loss-compensation mechanisms in Austria and Denmark

Label
Compensation of losses in foreign subsidiaries within the EU : a comparative study of the unilateral loss-compensation mechanisms in Austria and Denmark
Title
Compensation of losses in foreign subsidiaries within the EU : a comparative study of the unilateral loss-compensation mechanisms in Austria and Denmark
Creator
Subject
Language
eng
Summary
This study commences in the problems related to the restricted possibilities for cross-border groups to take losses incurred in foreign subsidiaries into account upon taxation. These difficulties lead to the situation where the overall tax burden of the group, seen as an economic unit, might exceed its economic capacity. Such over taxation is likely to cause the cross-border group cash-flow disadvantages, liquidity problems, reduced expansion possibilities and it might also effect the organisation and location of the group's business activities. This study has two research aims: firstly to analyse unilateral compensation of losses in foreign subsidiaries de lege lata, and secondly to analyse the consequences of different alternatives, as well as refraining from taking specific measures, upon opening up a unilateral system to cover also foreign losses de lege ferenda. In these respects, the experiences from the Austrian and Danish unilateral loss-compensation systems, under which losses incurred in foreign subsidiaries are acknowledged, serve as valuable sources of information. The findings in the study are evaluated based on the fundamental objectives that ought to be balanced from the perspective of the group as well as the loss-granting state. These objectives are; the recognition of the ability of the cross-border group, seen as an economic unit, to pay taxes; the prevention of double dip of losses, and the prevention of arbitrary as well as permanent income shifting between Member States
http://library.link/vocab/creatorName
Gerson, A
Geographic coverage
European Union
Index
no index present
Language note
English
Literary form
non fiction
Series statement
JIBS Dissertation Series
Series volume
no. 058
http://library.link/vocab/subjectName
  • cross-border loss relief
  • foreign company
  • EU law
  • fundamental freedoms
  • justification
  • fiscal neutrality
  • entity approach
  • income splitting
  • double dipping
  • double taxation relief
Label
Compensation of losses in foreign subsidiaries within the EU : a comparative study of the unilateral loss-compensation mechanisms in Austria and Denmark
Instantiates
Publication
Extent
xv, 278 p.
Isbn
9789186345006
Label
Compensation of losses in foreign subsidiaries within the EU : a comparative study of the unilateral loss-compensation mechanisms in Austria and Denmark
Publication
Extent
xv, 278 p.
Isbn
9789186345006

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      52.37366609999999 4.9336932
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