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Corporate Taxation, Group Debt Funding and Base Erosion: New Perspectives on the EU Anti-Tax Avoidance Directive by BIZIOLI

Corporate Taxation, Group Debt Funding and Base Erosion: New Perspectives on the EU Anti-Tax Avoidance Directive

Edited by Gianluigi Bizioli, Mario Grandinetti, Leopoldo Parada, Giuseppe Vanz, Alessandro Vicini Ronchetti,
By Aitor Navarro Ibarrola, Andrés Báez Moreno, Daniel Reich, F. Alfredo Garcia Prats, Federica Pitrone, Giuseppe Melis, Harm van den Broek, Jakob Bundgaard, Marco Barassi, Michael Tell, Peter Essers, Werner Haslehner
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Overview

EUCOTAX Series on European Taxation, Volume Number 67.

About this book:
Corporate Taxation, Group Debt Funding and Base Erosion is the first in-depth analysis of the features and implications of the directive, and it provides insightful and practical discussions by experts from around Europe on the crucial interactions of the Anti-Tax Avoidance Directive (ATAD) with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms. The European Union’s (EU’s) ATAD, implemented in January 2019, confronts Member States with complex challenges, particularly through the introduction of specific permanent solutions such as the interest limitation rule. This book pays special attention to the complexities that the introduction of an interest limitation rule may create within the European financial sector.

What’s in this book:
The book is divided into three parts that ensure a proper understanding of the high level of technicalities involving the new ATAD interest limitation rule, as well as the main domestic challenges that Member States are facing with the implementation of this rule. Specific issues and topics covered include the following:

  • relation with the OECD’s Base Erosion and Profit Sharing project and the EU’s Common Corporate Tax Base initiative; 
  • technical subjects relating to corporate taxation and debt funding; 
  • problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies; 
  • exclusion clauses for interest expenses; and
  • interplay between interest limitation rules and anti-hybrid rules.

How this will help you:
This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States. A comparative analysis of implementation issues in four leading Member States—Germany, Italy, Spain and the Netherlands—as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated with the implementation of ATAD.

Last Updated 02/04/2020
Update Frequency As Needed
Product Line Kluwer Law International
ISBN 9789403511702
SKU 10071977-0001
Table of Contents

Editors 

Contributors 

PART I
The Interest Limitation Rule in the ATAD: Targeting Base Erosion 

CHAPTER 1
Group Debt Funding and Base Erosion: An Introduction
Peter Essers 

CHAPTER 2
The Preference of Debt over Equity for Tax Purposes
Jakob Bundgaard & Michael Tell 

CHAPTER 3
The Interest Limitation Rule in the ATAD
Mario Grandinetti 

CHAPTER 4
ATAD Interest Expenses Exclusion Clauses
Alessandro Vicini Ronchetti 

CHAPTER 5
Interest Limitation Rule and EU Law
Gianluigi Bizioli 

PART II
The Interest Limitation Rule in the ATAD: Issues of Implementation 

CHAPTER 6
Germany
Daniel Reich

CHAPTER 7
Italy
Giuseppe Vanz 

CHAPTER 8
Spain
Andrés Báez Moreno & Aitor Navarro Ibarrola

CHAPTER 9
The Netherlands
Harm van den Broek 

CHAPTER 10
Comparative Survey
Marco Barassi

PART III
The Interest Limitation Rule in the ATAD: BEPS and CCTB 

CHAPTER 11
The EU ATAD Interest Limitation Rule, BEPS and CCTB: The EU ATAD Rule and BEPS Action 4
F. Alfredo Garcia Prats 

CHAPTER 12
The ATAD and the CCTB
Werner Haslehner 

CHAPTER 13
The Interplay Between Interest Limitation Rules and Anti-hybrid Rules: Inverting the Paradigm
Leopoldo Parada 

CHAPTER 14
Some Reflections on Interest Limitation Rules and Financial Institutions
Federica Pitrone 

CHAPTER 15
Conclusions
Giuseppe Melis 

Index

Volumes