International and EC tax aspects of groups and companies / edited by Prof. Guglielmo Maisto.

Format:

Book

Contributor:

Maisto, Guglielmo.

Series:

EC and international tax law series , 1574-969X ; v. 4.

Language:

English

Physical Description:

564s. ; 23 cm.

Place of Publication:

Amsterdam : IBFD, 2008.

Summary:

Comprising the proceedings and working documents of an annual seminar held in Milan in November 2007, this book analyses the tax issues for groups of companies operating in a European or worldwide dimension. The book examines the issues raised by both tax treaty and European law by focusing on selected topics. It first provides an analysis of the group concept under company and commercial law followed by an overview of taxation of groups in common and civil law countries. The tax regime of groups of companies under European law is further considered, both for income tax and VAT. The issues raised by application of tax treaties to groups of companies is then considered, with a particular emphasis on treaty recognition of groups, application of tax treaties to companies included in national group consolidation regimes, and application of the treaty articles on business income and non-discrimination. Individual country surveys provide an in-depth analysis of the above issues from a national viewpoint in selected European and North American jurisdictions

Contents:

Ch. 1 Corporate group law in Europe : the status quo under company and commercial law / Susanne Kalssch. 2 The common law perspective on the international and EC aspects of groups of companies / Angelo Nikolakakisch. 3 Group taxation under domestic law : common law versus civil law countries / Frans Vanistendaelch. 4 The impact of EC law on groups of companies / Paul Farmerch. 5 European VAT and groups of companies / Andrea Parolinich. 6 Treaty recognition of groups of companies / Jacques Sassevillech. 7 Application of tax treaties to companies subject to national group taxation regimes / Simon Patrick Linkch. 8 Business income of tax groups in tax treaty law / Claus Staringerch. 9 Non-discrimination under tax treaties regarding groups of companies / Kees van Raadch. 10 Austria / Florian Bruggerch. 11 Belgium / Robert Neytch. 12 Canada / Kim Brooksch. 13 France / Nicolas Messagech. 14 Germany / Simon Patrick Linkch. 15 Italy / Fabrizio Bendottich. 16 The Netherlands / Pieter van der Vegtch. 17 Poland / Lukasz Adamczykch. 18 Spain / Emilio Cencerrado Millanch. 19 United Kingdom / Julian Ghoshch. 20 United States / Yariv Braunerch. 21 Round table : the summing up / Auqusto Fantozzi [and others]

Notes:

"NUR 826".

ISBN:

9087220286

9789087220280