This paper reflects the tabled novel framework for corporate taxation in the European Union, founded on the Formulary Apportionment methodology and envisaged inclusion of intangible assets in the allocation formula. The objective is to simulate the variation between the currently used Separate...

This paper examines the legal consequences and assesses the economic impact of the differing tax treatment of investment funds in Portugal, Germany, and Luxembourg before and after the Allianzgi-Fonds case decision. Before the Allianzgi-Fonds case decision the Portuguese investment taxation...

The paper discusses the European Commission’s tax policy agenda in business income taxation and the ongoing legislative initiatives in this regard as per early 2022. The focus is on the Commission Communication titled ‘Business Taxation for the 21st Century’ of 18 May 2021 and the...

This paper seeks to contribute to the current debate on EU-wide corporate taxation, steered by the impending Proposal by the European Commission on a new framework for the taxation of income of businesses in Europe. The objective of this paper is to verify whether the inclusion of intangible...

Die Forscher des ZEW Mannheim rund um Professor Christoph Spengel kommen zu folgendem Ergebnis: Der Steuerwettbewerb hat sich abgeschwächt. Bestimmte Instrumente gegen die Gewinnverlagerung wirken. Das führt aber bisher nicht zu einer Angleichung der Steuersätze auf niedrigerem Niveau.

The main aim of this study is to present the basic principles of taxing revenue derived from activities carried out by farmers in Poland, resulting from the regulations of tax law in Poland, and propose solutions concerning that law as it should stand. These are revenues derived from...

Im Laufe des Jahres 2023 plant die Europäische Kommission, einen Vorschlag für ein neues Körperschaftsteuersystem unter dem Titel "Business in Europe: Framework for Income Taxation (BEFIT)" vorzustellen. Im Kern geht es bei BEFIT um das Aufstellen von gemeinsamen Regeln innerhalb der...

The main aim of this study is to present the basic principles of taxing revenue derived from activities carried out by farmers in Poland, resulting from the regulations of tax law in Poland, and propose solutions concerning that law as it should stand. These are revenues derived from...

Die Arbeit befasst sich mit einer Analyse der bestehenden mehrwertsteuerrechtlichen Regelungen für die schweizerischen Reiseanbieter. Das Deutsche Bundesfinanzministerium will einseitig und ohne geänderte gesetzliche Grundlage Reiseanbieter mit Sitz ausserhalb der EU von der geltenden...

EU corporate tax policy has long consisted solely in eliminating fiscal barriers. This changed after the financial and Eurozone crises when the European Commission proposed ‘market-correcting’ provisions to increase tax transparency and ‘fairness’, which were partially adopted by the...

The European Court of Justice (‘ECJ’) recently examined the statutory provisions in the context of European Value Added Tax (‘VAT’) regulations to opine upon the extent of restrictions that can be imposed upon entities which are under liquidation. This decision addresses a situation...

Tax sovereignty under globalization is at risk of unraveling. This is not only–as is often argued—because international organizations or other states exert external power on sovereign states. It is also the very process of fragmentation of state sovereignty that undermines its own...

To ensure the neutrality of EU VAT, a supplier can (in principle) under Article 90 of the VAT Directive, reduce the taxable amount if – among other situations – the customer fails to pay for the supply (non-payment or 'bad debt'). Article 185 addresses the other side of the transaction and...

This study approaches a highly debated theme in the public finance area, the Value Added Tax's efficiency respectively. The first part is dedicated to highlight how VAT works as a consumption tax, the VAT spread, the advantages and drawbacks of VAT, and also VAT rules within the European Union....

The introduction of a formulaically apportioned common consolidated corporate tax base (CCCTB) could represent a milestone in international taxation. No agreement has yet been reached, however. In contrast, Germany already has a long-standing system that apportions corporate taxes by splitting...

This article provides a brief analysis of the Court of Justice of the EU decision of 16 March 2021, C 562/19 P European Commission v Republic of Poland, addressing issues of state aid and progressive turnover taxation

The theory of international macroeconomics shows that domestic tax policy in a global economy affects foreign economic conditions via complex, dynamic interactions through relative prices, tax revenues, and wealth distribution. This paper proposes a tractable quantitative framework for assessing...

The digital economy is shaking up our societies. Its disruptive effect is being felt even in the way we assess and collect taxes. This phenomenon, coupled with the internationalization of trade, makes tax situations more complex and becomes conducive to tax avoidance attempts. All players in the...

This paper evaluates the Common Consolidated Corporate Tax Base (CCCTB) recently proposed by the European Commission. We find that if the CCCTB is introduced as it is currently proposed (including loss consolidation), then it is likely to impose large tax revenue costs of about one fifth of the...

In the context of a stylised game theoretical framework of capital tax competition, we show that when repeated policy interactions are associated to a systematic punishment of the deviating policymaker, a co-ordinated outcome can be the solution to the non co-operative tax game. This result...

This paper evaluates the Common Consolidated Corporate Tax Base (CCCTB) recently proposed by the European Commission. We find that if the CCCTB is introduced as it is currently proposed (including loss consolidation), then it is likely to impose large tax revenue costs of about one fifth of the...

This paper aims to contribute to the European policy debate on corporate income tax reform in three ways. First, it takes a step back to review the performance of the CIT in Europe over the past several decades and the important role played by MNEs in European economies. Second, it analyses...

Anfang 2021 hat die Europäische Kommission den formalen Prozess zur Entwicklung eines stabilen regulatorischen und steuerlichen Rahmens zur Bewältigung der Herausforderungen der digitalen Wirtschaft wieder aufgenommen. Bereits 2018 wollte die Europäische Kommission eine politische Einigung...

As of the beginning of 2021, the European Commission has restarted the formal process to develop a stable regulatory and tax framework to address the challenges of the digital economy. In 2018, the European Commission initially intended to gain political agreement on a Digital Services Tax (DST)...

This study evaluates the economic effects of corporate tax coordination in the enlarged European Union using a computable general equilibrium model and a comprehensive set of scenarios for both a common corporate EU tax base and for full harmonisation of tax bases and tax rates. Our main...

The planned full-scale implementation of the origin principle with the cross-border pre-tax system would lead, ceteris paribus, to changes in VAT revenues in the individual EU countries. For instance, the member countries with trade surpluses and higher VAT rates would be significantly better...

This paper analyzes the link between Foreign Direct Investment (FDI), corporate taxation, and corporate tax revenues. We find strong evidence that FDI in (out) flows are affected by tax regimes in the host (home) countries and FDI flows in turn affect the corporate tax base. Simulations of EU...

As economic integration within the European Union (EU) progresses, the interactions between the tax systems of the Member States are of growing importance. Member State tax policies can have spillover effects on other Member States and differing abilities to provide net fiscal benefits to...

In Europe, the competence for social security and the right to levy income tax lie with the country of employment in cross-border matters. This has two disadvantages. First, the Employment Principle distorts active persons' choice of place of work. Second, the employment-based regulation of...