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The Resource Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European Internal Market and the principles of territoriality and worldwide taxation

Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European Internal Market and the principles of territoriality and worldwide taxation

Label
Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European Internal Market and the principles of territoriality and worldwide taxation
Title
Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European Internal Market and the principles of territoriality and worldwide taxation
Creator
Subject
Language
  • eng
  • eng
Summary
The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriality or on the principle of worldwide taxation, are in conflict with the objective of achievement of the internal market. This objective is indeed difficult to reach when it comes to the taxation of foreign income, given that the Member States are far from taxing companies doing business cross-border as if their operations were purely domestic. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation and the attribution of profits to permanent establishments. This dissertation analyses this conflict on the basis of a study of the case law of the European Court of Justice as well as some of the key provisions of the European treaties. It appears that both the fiscal principle of territoriality and the principle of worldwide taxation give rise to complex issues of compatibility with the law of the European Union. Although the analysis conducted throughout the dissertation provides some guidance for the taxation of the foreign business income of companies, it is concluded that the Court cannot, by itself, efficiently resolve the conflict between such taxation and the objective of achievement of the internal market
http://library.link/vocab/creatorName
Monsenego, J. (Jérôme)
Geographic coverage
  • European Union
  • Europe
Index
no index present
Language note
English
Literary form
non fiction
Series statement
IBFD Doctoral Series
Series volume
22
http://library.link/vocab/subjectName
  • business profits
  • foreign source income
  • territoriality principle
  • worldwide income
  • ECJ case law
  • internal market
Label
Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European Internal Market and the principles of territoriality and worldwide taxation
Instantiates
Publication
Extent
xviii, 396 p.
Isbn
9789087221133
Isbn Type
(print)
Issn
1570-7164
Note
20120305
Label
Taxation of foreign business income within the European internal market : an analysis of the conflict between the objective of achievement of the European Internal Market and the principles of territoriality and worldwide taxation
Publication
Extent
xviii, 396 p.
Isbn
9789087221133
Isbn Type
(print)
Issn
1570-7164
Note
20120305

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