Description |
1 online resource (340 pages). |
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text file |
Series |
Cambridge tax law series
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Cambridge tax law series.
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Contents |
Cover; The Taxation of Corporate Groups Under Consolidation; Series; Title; Copyright; Contents; Figures; Tables; Preface; Glossary of terms; Abbreviations; PART I The enterprise doctrine: theory and practice; 1 The rise of corporate groups: a challengeto the tax law; 1.1 The rise of corporate groups; 1.2 Tension between traditional legal principle and commercial reality; 1.3 Tax consolidation: a response to the rise of corporate groups; 1.4 The purpose, analytical approach and content of this book; 2 Application of the enterprise doctrine to group taxation:; 2.1 The separate entity doctrine. |
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2.1.1 Historical development of legal personality of companies2.1.2 Companies as separate taxable units; 2.1.3 The rise of corporate groups: a challenge to the doctrine; 2.2 The enterprise doctrine; 2.2.1 Development of the enterprise doctrine in corporation law; 2.2.2 The enterprise doctrine and the tax law; 2.2.3 Why is the enterprise doctrine more appropriate for the taxation of corporate groups?; 2.2.3.1 Criteria to judge a tax regime; 2.2.3.1 Criteria to judge a tax regime; 2.2.3.2 Justifications to apply the enterprise doctrine to group taxation regimes; (1) Simplicity; (1) Simplicity. |
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2.2.3.2 Justifications to apply the enterprise doctrine to group taxation regimes(1) Simplicity; (1) Simplicity; (2) Fairness; (2) Fairness; (2) Fairness; (2) Fairness; (3) Neutrality; (3) Neutrality; (3) Neutrality; (3) Neutrality; (4) Competitiveness; (4) Competitiveness; (4) Competitiveness; (4) Competitiveness; 2.3 Key dimensions of application of the enterprise doctrine; 2.3.1 Taxable unit; 2.3.2 Tax base; (1) Relationship to international tax norms; (1) Relationship to international tax norms; (2) Possible definition of tax base under the enterprise doctrine. |
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(I) A country group as the taxable unit(i) A country group as the taxable unit; (2) Possible definition of tax base under the enterprise doctrine; (i) A country group as the taxable unit; (i) A country group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; (ii) A bloc group or worldwide group as the taxable unit; 2.4 Taxonomy of group taxation models under the enterprise doctrine; 3 Application of the enterprise doctrine to group taxation. |
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3.1 Key dimensions of application of the enterprise doctrine in practice(1) Taxable unit; (2) Tax base; 3.2 Application of the enterprise doctrine: corporate groups as taxable unit; (1) Group pooling; (2) Consolidation; (3) Consolidation of a bloc group -- CCCTB; (4) Worldwide group pooling; 3.3 Application of the enterprise doctrine: tax base of a company; (1) Tax free intra-group asset transfer22; (2) Group contribution; (3) Group loss relief; (4) Organschaft26; (5) Water's edge FA; (1) Combination of models; (2) Residence concept33; (3) Ideas vs reality. |
Note |
3.4 Application of the enterprise doctrine: key functions of a group taxation regime. |
Summary |
Antony Ting presents the first comprehensive comparative study of the tax consolidation regimes adopted in eight countries. |
Bibliography |
Includes bibliographical references and index. |
Local Note |
eBooks on EBSCOhost EBSCO eBook Subscription Academic Collection - North America |
Subject |
Corporations -- Taxation -- Law and legislation.
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Corporations -- Taxation -- Law and legislation. |
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Income tax -- Law and legislation.
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Income tax -- Law and legislation. |
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Fiscal policy.
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Fiscal policy. |
Genre/Form |
Electronic books.
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Electronic books.
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Other Form: |
Print version: Ting, Antony. Taxation of Corporate Groups under Consolidation : An International Comparison. Cambridge : Cambridge University Press, ©2012 9781107033498 |
ISBN |
9781139616843 |
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1139616846 |
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9781283870702 (MyiLibrary) |
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1283870703 (MyiLibrary) |
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9781139626149 (electronic book) |
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1139626140 (electronic book) |
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9781139519786 (electronic book) |
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1139519786 (electronic book) |
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9781107033498 |
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1107033497 |