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The Resource Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform

Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform

Label
Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform
Title
Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform
Creator
Subject
Language
  • eng
  • eng
Summary
This book provides a disruptive discourse on tax sovereignty in the field of corporate income taxation that endeavours to escape from long-standing tax policy tendencies and prejudices while considering the challenges posed by a globalized (and increasingly digitalized) economy. In particular, the book offers an innovative perspective on certain deep-rooted paradigms historically underlying corporate income taxation: tax treatment of related parties within a corporate group along with the arm's-length standard; corporate tax residence standards; and definition of source for corporate income tax purposes, with a particular emphasis on the permanent establishment concept. The book explores their respective origins, supposed tax policy rationales, structural problems and interactions; ultimately showing how the way tax jurisdiction is currently defined through them inherently tends to trigger profit shifting outcomes. In view of the conclusions of the study, the author suggests the use of a new version of the traditional benefit principle (the "presumptive benefit principle") that would contribute to address the profit shifting phenomenon while serving as a practical guideline to achieve a more equitable allocation of taxing rights among jurisdictions. Finally, the book submits a number of proposals inspired by the aforementioned guideline that aspire to strike a balance between equity, effectiveness and technical feasibility. They include a new corporate tax residence test and, most notably, a proposal on a new remote-sales permanent establishment
http://library.link/vocab/creatorName
Escribano, E
Geographic coverage
  • International
  • European Union
Index
no index present
Language note
English
Literary form
non fiction
Series statement
Series on international taxation
Series volume
70
http://library.link/vocab/subjectName
  • corporate income tax
  • tax sovereignty
  • benefit principle
  • tax reform
  • allocation of taxing rights
  • cross-border transaction
  • profit shifting
  • arm's length principle
  • residence
  • PE
Label
Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform
Instantiates
Publication
Extent
xxvii, 299 p.
Isbn
9789403506449
Isbn Type
(e-Book)
Note
20190703
Label
Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform
Publication
Extent
xxvii, 299 p.
Isbn
9789403506449
Isbn Type
(e-Book)
Note
20190703

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
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