European Union Corporate Tax Law

ISBN-13: 9781108839020 / Angielski / Twarda / 2021 / 450 str.

Christiana H. J. I. Panayi (Queen Mary University of London)

Opis

How does EU law affect Member State corporate tax systems and the cross-border activities of companies? This book traces the historical development of EU corporate tax law and provides an in-depth analysis of a number of issues affecting companies, groups of companies, and permanent establishments. Christiana HJI Panayi examines existing legislation, soft law, and the case law of the Court of Justice, as well as the Commission's burgeoning external tax policy initiatives. The book not only explores the tax issues pertaining to direct investment, but also analyzes the taxation of passive investment income, corporate reorganisations, exit taxes, and the treatment of anti-abuse regimes. Through this careful analysis, the book highlights the convergences and divergences arising from the interplay between EU corporate tax law and international tax law, especially the OECD model tax convention. This second edition also reviews developments in the context of the State aid prohibition and high-profile cases on tax rulings.

Recenzje

'The strength of the book lies in its holistic approach towards primary and secondary EU law in the field of corporation tax law, and in the meticulous and learned analysis of CJEU case law and its ramifications. It is therefore of great value as a textbook for students, as well as for practitioners who look for a systematic and concise handbook to familiarise themselves with the central elements of this area of law.' Joachim Englisch, British Tax Review

Spis treści

Foreword; Preface; 1. The historical background to EU corporate tax law; 2. EU corporate tax legislation; 3. The Court of Justice and the development of EU corporate tax law; 4. Tax obstacles to the cross-border movement of companies: direct investment; 5. Tax obstacles to cross-border portfolio investment; 6. Reorganisations under EU tax law; 7. Tax avoidance and EU law; 8. State aid and taxation; 9. EU corporate tax law: more interim conclusions and thoughts.