Taxation of Foreign Business Income Within the European Internal Market

Taxation of Foreign Business Income Within the European Internal Market

4.11 - 1251 ratings - Source



The rules of the Member States on the taxation of the foreign business income of companies, whether such rules are based on the fiscal principle of territoriality or on the principle of worldwide taxation, are in conflict with the objective of achievement of the internal market. This objective is indeed difficult to reach when it comes to the taxation of foreign income, given that the Member States are far from taxing companies doing business cross-border as if their operations were purely domestic. Areas of conflict include particularly the taxation of foreign profits, the deduction of foreign losses, the elimination of international double taxation and the attribution of profits to permanent establishments. This dissertation analyses this conflict on the basis of a study of the case law of the European Court of Justice as well as some of the key provisions of the European treaties. It appears that both the fiscal principle of territoriality and the principle of worldwide taxation give rise to complex issues of compatibility with the law of the European Union. Although the analysis conducted throughout the dissertation provides some guidance for the taxation of the foreign business income of companies, it is concluded that the Court cannot, by itself, efficiently resolve the conflict between such taxation and the objective of achievement of the internal market.Chapter. 6. a€œ[Y-]a-t-il plus belle entrave An la libre circulation que la double imposition juridique?a€700 ... Compatibility issues with EU law were identified and some conclusions were made on the desirable extent of Member Statesa#39; tax jurisdiction in order to achieve the internal market. ... to the compatibility with EU law of the principle of worldwide taxation. of the Internal Market tion.702 It is submitted that aanbsp;...


Title:Taxation of Foreign Business Income Within the European Internal Market
Author: Jérôme Monsenego
Publisher:IBFD - 2012
ISBN-13:

You must register with us as either a Registered User before you can Download this Book. You'll be greeted by a simple sign-up page.

Once you have finished the sign-up process, you will be redirected to your download Book page.

How it works:
  • 1. Register a free 1 month Trial Account.
  • 2. Download as many books as you like (Personal use)
  • 3. Cancel the membership at any time if not satisfied.


Click button below to register and download Ebook
Privacy Policy | Contact | DMCA