The Resource Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies
Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies
Resource Information
The item Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- Neutrality with regard to import and export neutralities influences direct taxation of companies. The parent company can compete to finance its subsidiary by means of a loan or by increasing its shareholdings. There is no neutrality in the form of funding of the companies located in countries that contemplate average or high taxation for business profits, because there are expectations of fiscal planning. To avoid these situations, the countries of residence of the subsidiaries of a financial centre or parent company lender protect their tax bases through a classic special anti-tax avoidance measure: thin capitalization. The compatibility of the thin capitalization with the Organisation for Economic Co-operation and Development (OECD) Model calls for a flexible thin capitalization rule, instead of ratios or rigidly predetermined coefficients
- Language
- eng
- Label
- Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies
- Title
- Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies
- Language
- eng
- Summary
- Neutrality with regard to import and export neutralities influences direct taxation of companies. The parent company can compete to finance its subsidiary by means of a loan or by increasing its shareholdings. There is no neutrality in the form of funding of the companies located in countries that contemplate average or high taxation for business profits, because there are expectations of fiscal planning. To avoid these situations, the countries of residence of the subsidiaries of a financial centre or parent company lender protect their tax bases through a classic special anti-tax avoidance measure: thin capitalization. The compatibility of the thin capitalization with the Organisation for Economic Co-operation and Development (OECD) Model calls for a flexible thin capitalization rule, instead of ratios or rigidly predetermined coefficients
- Citation source
- In: Intertax. - Alphen aan den Rijn. - Vol. 38 (2010),
- http://library.link/vocab/creatorName
- García Novoa, C
- Geographic coverage
-
- European Union
- Europe
- Language note
- English
- http://library.link/vocab/subjectName
-
- fiscal neutrality
- thin capitalization
- fundamental freedoms
- Label
- Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies
- Label
- Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Tax-neutrality-in-the-exercise-of-the-right-of/iSs8KZ91O0o/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Tax-neutrality-in-the-exercise-of-the-right-of/iSs8KZ91O0o/">Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Tax-neutrality-in-the-exercise-of-the-right-of/iSs8KZ91O0o/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Tax-neutrality-in-the-exercise-of-the-right-of/iSs8KZ91O0o/">Tax neutrality in the exercise of the right of establishment within the EU and the funding of companies</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
