EU Freedoms, Non-EU Countries and Company Taxation (Eucotax by D. S. Smit

By D. S. Smit

In today’s atmosphere of mostly globalizing nationwide economies, foreign fiscal integration doesn't cease on the frontiers of the eu Union. Many non-EU-based organizations are sporting on enterprise within the eu Union in the course of the operation of branches or subsidiaries validated in european Member States, and a lot of EU-based corporations hold a various variety of investments open air the Union. as a result, in either inward and outward funding relationships, ‘economic openness’ is essential these days. This criminal courting among european Member States and the ecu as an entire vis-à-vis the remainder of the realm is the place to begin of this publication. the writer analyses the ‘freedom of funding’ notion among european Member States and non-EU States below european legislations, and in particular its influence on corporation taxation regimes, from the viewpoint of firm corporations. targeting the influence of the Treaty freedoms and overseas integration agreements on family members with non-EU Member States, this paintings is the 1st to in particular deal with the all-important factor: below which conditions can investment-related rights deriving from ecu legislation be invoked by way of businesses tested in non-EU states? The research identifies the influence of the european Treaty freedoms on six uncomplicated company source of revenue tax subject matters which are of specific curiosity for multinational firms: trouble at the deduction of curiosity bills; withholding taxes on dividend, curiosity, and royalty funds; reduction for double taxation of source of revenue acquired from overseas investments; CFC laws; non-deduction of overseas losses from the family taxable base; and corporate taxation upon the transnational move of industrial assets.

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