Corporate tax residence and mobility
Subtitle: 2017 EATLP Congress Łódź, 1-3 June 2017
By: editor, Edoardo Traversa
Series: EATLP international tax series -- volume 16; EATLP international tax series -- v. 16
Publisher: IBFD
Published: 2018
Place of publication: Amsterdam, The Netherlands
Language: eng
Number of pages: 731
ISBN-13: 9789087224516; 9789087224400
Copyright date: 2018
Subjects: Corporations; Taxation; Congresses; International business enterprises; Law and legislation; Domicile in taxation
Description: The concept of residence lies at the core of corporate income taxation. In domestic tax systems, the essential function of the residence concept is to subject resident corporate taxpayers to full tax liability, usually on a worldwide basis. In tax treaties, residence plays a fundamental role in the allocation of taxing powers between states. Moreover, within the European Union, it gives access to the legal protection granted to companies by internal market rules, whether contained in EU treaties (fundamental freedoms) or in tax directives.0 0Today, however, the globalization and the digitalization of the economy are putting residence under heavy pressure. Within multinational enterprises, the geographical dislocation of the functions performed by people and entities within the multinational group makes it harder to identify a central place of decision or management in cases where this place is not the same as the place where the company was incorporated. Moreover, tax planning strategies involving location or the transfer of residence to low-tax jurisdictions have come under the spotlight of international organizations, such as the OECD and the European Union.0 0Against this background, this book examines the notion of residence from a comparative, EU and international law perspective.--
Notes: "This book contains the proceedings of the annual meeting of the European Association of Tax Law Professors held in Łódź (Poland) from 1-3 June 2017"--Page v.

Includes bibliographical references.