Company Tax Reform in the European Union

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November 2005



Having spent almost fifty years of my life defending the separate accou- ing, arm's length pricing method, I have to admit that I was somewhat surprised to be asked to contribute to a book suggesting that the European Union might do well to consider adopting a formulary approach to deal with the taxation of inter and intra company transactions. I was even more surprised to see the invitation coming from Ms. Joann Weiner an ardent co-defender of arm's length pricing and my strong right arm in that regard while we both served in the U.S. Treasury Department in the mid '90s. The book gives Ms Weiner the opportunity to comment frankly from an insider's perspective of the many admitted problems of the arm's length system which could be avoided by a formulary approach. Ms. Weiner brings to this project a thorough expert knowledge of the b- efits and shortfalls of each of the systems she discusses - separate accounting v. formulary apportionment. Who better to decide to give qualified support to formulary than someone who organized a U.S. Treasury conference to defend arm's length pricing against a Congressional challenge in favor of formulary apportionment.


Company Tax Reform and Formulary Apportionment in the European Union.
The Landscape for EU Company Tax Reform.
Formulary Apportionment in the European Union.
The Apportionment Formula.
Nexus, The Tax Base and the Taxable Unit.
Tax Administration, Compliance and Tax Planning.
Economic Analysis of Formulary Apportionment.
Conclusion: Implementing Formulary Apportionment in the European Union.
EAN: 9780387294247
ISBN: 0387294244
Untertitel: Guidance from the United States and Canada on Implementing Formulary Apportionment in the EU. 2006. Auflage. Book. Sprache: Englisch.
Verlag: Springer
Erscheinungsdatum: November 2005
Seitenanzahl: 144 Seiten
Format: gebunden
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