Commission proposal for home state taxation

Journal
Author
Thömmes, O.; Rasch, S.; Koch, T.
Country
European Union
Published Date
Issue
International Transfer Pricing Journal 2006 (Volume 13), No. 3
FormatPDF
EUR
45
| USD
50 (VAT excl.)

Here, the authors present their own analysis of the Commission's Home State Taxation Proposal. Some unexpected effects are described, e.g. like distortion of competition (between participating and non-participating SMEs), and tax planning opportunities within groups. Subsequently, the required formulatory apportionment is discussed, e.g. whether the same formula can be applied to all business sectors. Relevant factors constitute assets, sales and payroll, which are each of them examined. The article finishes with an analysis of the prerequisites for participation in the pilot and an assessment of the scope of a possible pilot.