The Resource Exemption method for PEs and (major) shareholdings best services : the CCCTB and the internal markets concerned

Exemption method for PEs and (major) shareholdings best services : the CCCTB and the internal markets concerned

Label
Exemption method for PEs and (major) shareholdings best services : the CCCTB and the internal markets concerned
Title
Exemption method for PEs and (major) shareholdings best services : the CCCTB and the internal markets concerned
Creator
Subject
Language
eng
Summary
This article focuses on one of the international tax consequences of the introduction of a common consolidated corporate tax base (CCCTB): the exemption for permanent establishments (PEs) and major shareholdings, which implies that the profits attributable to a PE and profits by virtue of a major shareholding (dividend and capital gains) are exempt from taxation in order to avoid double taxation. It considers the establishment of internal markets as leading argument for eliminating double taxation, capital and labour import neutrality, the legal principles of a tax base exemption for income from PEs and shareholdings, and the tax base exemption under attack at the European Court of Justice (Stahlwerk Ergste Westig, Lidl Belgium, and Deutsche Shell)
Citation source
In: EC tax review. - Alphen aan den Rijn. - Vol. 17 (2008),
http://library.link/vocab/creatorName
Kemmeren, E.C.C.M
Geographic coverage
  • European Union
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • CCCTB
  • corporate income tax
  • exemption
  • PE
  • substantial shareholding
  • ECJ case law
Label
Exemption method for PEs and (major) shareholdings best services : the CCCTB and the internal markets concerned
Instantiates
Publication
Label
Exemption method for PEs and (major) shareholdings best services : the CCCTB and the internal markets concerned
Publication

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