Corporate Taxation, Group Debt Funding and Base Erosion : New Perspectives on the EU Anti-Tax Avoidance Directive

Bizioli, Gianluigi (EDT); Grandinetti, Mario (EDT); Parada, Leopoldo (EDT); Vanz, Giuseppe (EDT); Ronchetti, Alessandro Vicini (EDT)

ISBN 10: 9403511702 / ISBN 13: 9789403511702

Edité par Wolters Kluwer, 2020

A propos de cet article

N° de réf. du vendeur 42423164-n

Détails bibliographiques

• Titre: Corporate Taxation, Group Debt Funding and Base Erosion : New Perspectives on the EU Anti-Tax Avoidance Directive
• Éditeur: Wolters Kluwer
• Date de parution: 2020
• Langue: anglais
• ISBN à 10 chiffres: 9403511702
• ISBN à 13 chiffres: 9789403511702
• Reliure: Couverture rigide
• État de l'article: New

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Synopsis

The EU's Anti-Tax Avoidance Directive (ATAD), implemented in January 2019, confronts Member States with complex challenges, particularly via the introduction of an interest limitation rule. This timely book, the first in-depth analysis of the features and implications of the directive, provides insightful and practical discussions by experts from around Europe on the crucial interactions of the ATAD with other existing anti-tax avoidance measures, the European financial sector and the fundamental freedoms.

Specific issues and topics covered include the following:

• relation with the OECD's Base Erosion and Profit Sharing project (BEPS) and the EU's Common Corporate Tax Base initiative;
• technical subjects relating to corporate taxation and debt funding;
• problems caused by the diametrically opposite tax treatment of debt and equity within a group of companies;
• exclusion clauses for interest expenses; and
• interplay between interest limitation rules and anti-hybrid rules.

A comparative analysis of implementation issues in four leading Member States--Germany, Italy, Spain and The Netherlands--as well as a global general survey with regard to interest limitation rules allow readers to assess the particular complexities associated to the implementation of the ATAD.

This matchless commentary by leading European tax law academics and practitioners on an important and much-debated item of EU legislation gives practitioners, enterprises and tax authorities an early opportunity to understand the practical effects of the directive in the various Member States.

À propos de l'auteur

Gianluigi Bizioli is Professor of Tax Law and International and EU Tax Law in the Department of Law at the University of Bergamo. He also teaches Tax Law at the Accademia della Guardia di Finanza in Bergamo. He is Member of the Board of Professors of the Ph.D. Program in Business and Law of the University of Bergamo and Co-Director of the Rivista di Diritto Finanziario e Scienza delle Finanze. He is Author of more than ninety books and articles, especially in the field of constitutional tax law and European and International tax law. Since 2018 he is the Italian member of the Academic Committee of the European Association of Tax Law Professors and Of Counsel at the Italian practice of PwC Tax and Legal Services. Mario Grandinetti is a researcher and assistant professor of Tax Law at the University of Turin, where he regularly lectures both undergraduate (Tax Law) and graduate (International, European and Comparative Tax Lax) courses. In 2018, he was habilitated to Associate Professorship by the National Scientific Committee. He holds a Ph.D. in Public and Tax Law in the European dimension from the University of Bergamo (Italy) and has been a visiting researcher at several institutions, for example the Max Planck Institute in Intellectual Property and Tax Law of Munich (Germany) and the University of Valencia (Spain). In 2010, he was awarded a scholarship for young researchers by the Giovanni Goria Foundation. Mario authored a monograph and several contributions published on journals and in books, both in Italy and abroad. He also edited the book Corporate Tax Base in the Light of the Ias/Ifrs and Eu Directive 2013/34. A Comparative Approach. Dr. Leopoldo Parada, L.L.M., is a lecturer in Tax Law at the University of Leeds School of Law in the United Kingdom. He is also Visiting Professor of International and EU Tax Law at the University of Turin in Italy. Formerly, he worked as a research associate at the Max Planck Institute for Tax Law and Public Finance in Munich and held a postdoctoral research position at the IBFD in Amsterdam. In the past, he also practiced full-time as a lawyer and tax advisor in Chile, Brazil and the United States. He is a member of the Tax Committee of Experts of the Joint Italian Arab Chamber of Commerce (JIACC), the Chilean Bar Association and a former member of the American Bar Association (ABA) Section of Taxation. Giuseppe Vanz is an associate professor of Tax Law in the Department of Management at the University of Turin in Italy. He graduated in Law at the University of Turin and is Author of two monographs: I poteri conoscitivi e di controllo dell amministrazione finanziaria, Cedam ed., 2012, concerning the investigation powers of the tax authorities, and, together with I. Manzoni, Il diritto tributario. Profili teorici e sistematici, Giappichelli ed., 2008, concerning the general profiles of tax law. He is also the author of articles in different areas of tax law. He is admitted to the bar and practices before the Supreme Court in Italy. Alessandro Vicini Ronchetti is a researcher and assistant professor of Tax Law at the University of Turin, where he regularly lectures both undergraduate (Tax Law) and graduate (International, European and Comparative Tax Lax) courses. In 2017, he was habilitated to Associate Professorship by the National Scientific Committee. He holds a Ph.D. in International and European Tax Law from the University of Genoa (Italy) and has been a visiting researcher at the University of Valencia (Spain). His areas of expertise are domestic company taxation, European and International Taxation, VAT and the Taxation of Groups. Alessandro authored a monograph and several contributions published on journals and in books.