Descargar Libro: Cahiers De Droit Fiscal International

Resumen del Libro

The tax treatment of corporate losses is a broad, important subject, making it a topic ripe for coverage in a single, reliable resource. This work provides that needed coverage, addressing the tax treatment of corporate losses constituting real economic losses in companies, both domestic & cross-border. The book begins by examining the tax treatment of losses in a company organised as a single entity. This includes a discussion of time restrictions concerning the access to carry-forward & carry-back losses & other restrictions, such as basket limitations, restrictions concerning changes in the ownership of tax-loss companies, & anti-avoidance provisions. The work then examines the tax treatment of losses within a group. Again, both domestic & foreign losses receive attention. An evaluation of countries policy reasons for applying the various rules & restrictions on carrying over corporate losses receives particular attention. This subject matter gives rise to a number of difficult, complex problems relating to national law, European Union law, & tax treaty law. Legal & economic concerns add another layer of conflicting views. By providing & comparing the reports of a range of states, this work heightens awareness of the various issues & perspectives involved.