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Integration Approaches to Group Taxation in European Internal Market by Ioanna Mitroyanni

Integration Approaches to Group Taxation in European Internal Market

By Ioanna Mitroyanni


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The creation of a group taxation framework to subject affiliated entities resident in more than one EC Member State to a single set of rules is an experiment without precedent. Group taxation normally deals with tax liability in the context of a single jurisdiction. There is no system of group taxation worldwide which embraces more than one fiscal jurisdiction under a single regulatory umbrella.

This thought provoking work explores the prospect for creating a group taxation system extending across national borders in the EC. The objective is to specify what shape the elements of such a system should take as well as to identify the areas of complexity or probable impasse.

Among the topics covered:

  • The relevant jurisprudential and legislative framework of the European Internal Market;
  • A survey of the tax systems of Canada, Switzerland and the US with a focus on the principles pertaining to the division of power between the federal and sub-federal tiers;
  • The policies for corporate taxation in integrated markets;
  • Administrative concerns: compliance, enforcement, dispute resolution and re-assessment of tax liability;
  • Tests for entitlement to group membership;
  • Tax base integration; - Territorial delineation of the group; and
  • Formulary apportionment.

In sum, this book provides valuable insights into an area of significant importance to taxpayers, their advisors and policymakers as well.

Resources DM Piece
Last Updated 11/24/2008
Product Line Kluwer Law International
ISBN 9789041127792
SKU 10059202-0001
Table of Contents

Dedication. Acknowledgements. Introduction. 1. The Jurisprudence of the ECJ Relevant to Groups 2. Positive Integration Relevant to Groups 3. Deriving Examples from Corporate Tax Systems at Sub-Federal Level: Canada, Switzerland and the United States of America 4. Policy Approaches to Corporation Taxes in Closely Integrated Markets 5. Entitlement to Membership of the Group 6. The Group Tax Base 7. International Aspects 8. Formulary Apportionment 9. Administrative Issues. Bringing Together the Elements of the Scheme. Bibliography. Legislation. Policy Documents. List of Cases