Spis treści - Corporate taxation in the European Union
Master Thesis
E-book
za 88.2
drukowana A5
za 98.07
- Chapter 1 — Introductory remarks
- Preface
- The scope of the thesis
- Chapter 2 — Basic concepts and principles of the EU Tax law
- Introduction to basic concept of the EU Tax law
- Sources of EU law
- Primary law
- Secondary law
- Interpretation of EU law
- Internal Market and basic freedoms
- Introduction to the concept of the Internal Market
- Non-discrimination principle
- The fundamental freedoms
- Balancing free movement against other interests
- Justifications accepted by the CJEU
- Chapter 3 — The impact of primary EU law on corporate taxation
- Introductory remarks
- Free movement of goods
- The scope of application
- Impact on direct taxation
- The right of establishment
- Relevance and the scope of application
- The impact on the corporate taxation
- Permanent establishment
- The right of reincorporation
- Subsidiaries abroad
- Free movement of capital and payments
- The scope of application
- Impact on corporate taxation
- Free movement of services
- The scope and application
- Relevance to Corporate taxation
- Order of priority of the fundamental freedoms
- Freedom to provide services or free movement of capital?
- Freedom of establishment over free movement of capital?
- Freedom of goods or free movement of capital?
- Chapter 4 — Corporate Tax Directives
- Introduction to corporate taxation within EU
- Parent-Subsidiary Directive
- Scope of application
- Distribution of profits & Profit distribution
- Company of a Members State
- Permanent establishment
- Parent and subsidiary company
- Tax treatment of inbound dividends
- Amendment to Parent-Subsidiary Directive
- Hybrid entities
- The non-deductibility of charges related to the holding
- Tax treatment of outbound dividends
- Interest-Royalty Directive
- Scope of application
- Cross-border transactions
- Tax treatment
- Procedural requirements
- Merger Directive
- Scope of application
- General definitions
- Merger
- Division and partial division
- Transfer of assets
- Exchange of shares
- Operations outside the scope of the Merger Directive
- Tax treatment
- Chapter 5 — State aid discipline
- Introduction to the role of State aid law in the EU
- Basic criteria to establish whether measure constitutes unlawful state aid
- Notion of ‘state aid’
- Tax advantage
- State resources
- Affectation of trade
- Selectivity of certain undertakings
- Criteria for selectivity test
- Specific issues concerning tax rulings and settlements
- Procedural aspects of state aid under EU law
- Chapter 6 — Concluding remarks
- The future of corporate taxation in European Union
- Conclusion
- Bibliography — in the order of appearance
- Literature
- Case law
- Legal acts
- Other references
E-book
za 88.2
drukowana A5
za 98.07