Dourado, Ana Paula and de la Feria, Rita (2008) CCCTB: Thin Capitalization and Inbound Investment. In: Lang, Michael, Pistone, P., Schuch, J. and Staringer, C., (eds.) Common Consolidated Corporate Tax Base. Linde Verlag.Full text not available from this repository.
In the context of the proposed European CCCTB there is clearly a perceived need for the introduction of a common thin capitalization rule. This rule would be aimed at dealing with inbound investment emerging from both third countries, and from Member States opting out of the CCCTB. The principal aim of this paper is to establish whether such a need does indeed exist, and if so, which considerations should guide the design of a thin capitalization rule for the CCCTB. The paper starts by providing a broad summary of the varying approaches of Member States to thin capitalization. It then makes the case for the introduction of a thin capitalization rule in the context of the CCCTB, from both an economic and a legal perspective, and sets out the general principles which should guide the design of such a rule.
|Item Type:||Book Section|
|Keywords:||Taxation, thin capitalization|
|Centre:||Oxford University Centre for Business Taxation|
|Date Deposited:||19 Aug 2010 10:06|
|Last Modified:||21 Sep 2016 11:46|
Actions (login required)