000			03193nab a2200289 c 4500
999			_c142928 _d142928
003			ES-MaIEF
005			20210824122134.0
007			ta
008			201008t2020 ne ||||| |||| 00| 0|eng d
040			_aES-MaIEF _bspa _cES-MaIEF
041			_aeng
100			_aWilde, Maarten F. de _958102
245			_aOn the future of business income taxation in Europe _c Maarten de Wilde _hElectrónico
260			_c2020
500			_aDisponible únicamente en formato electrónico.
500			_aResumen.
520			_aHow should Europe respond to society’s calls for a sound and properly functioning corporate tax system for the internal market? With the aim of contributing to the deliberations on this subject, the proposal of the author is for the EU Member States to jump ahead in the debate and remodel the CCTB/CCCTB draft directives into a new system of international taxation, i.e. a unitary taxation model for taxing the worldwide economic profits of multinationals, using a destination-based apportionment formula (CCCTB 2.0) to apportion the tax base to countries both within and outside the European Union. Under such a system, it would be up to the EU Member States themselves to determine the rate applying to the tax base apportioned to them. This would take tax out of the equation in the case of marginal financing and investment decisions, while also curtailing its influence on investment location decisions and, at the same time, making “gaming the system” more difficult. EU Member States would, in turn, regain their autonomy to set their corporate tax rates at the levels they regard as appropriate, while the proposed model would also end the “race to the bottom” within the European Union. If the European Union were to be the first mover, self-interest would prompt other countries and regions to follow its lead. The resulting production location neutrality would encourage international businesses to embrace the model and lobby for transition as rapidly as possible. Driven by self-interest and competitive responses, such a move could initiate a transition to the worldwide adoption of destination-based taxation of excess earnings – in other words, harmonization through competition. As the innovator, the European Union would enjoy the greatest economic benefit during the transitional period, when countries’ profit tax systems would be evolving towards an equilibrium in which destination-based tax would become the new global standard. The final destination would be a new destination-based company tax paradigm operating both neutrally and non-discriminatorily on the supply side. That would produce a result that would not only be fair, but would also – and primarily – provide a systemic and economically efficient solution for the international problem of BEPS.
650		4	_aPOLITICA FISCAL _948067
650		4	_948426 _aSISTEMA FISCAL
650		4	_967871 _aREFORMA
650		4	_aSOCIEDADES _948454
650		4	_aTIPO MÍNIMO GLOBAL _967681
650		4	_959364 _aBASE IMPONIBLE COMÚN CONSOLIDADA
650		4	_967061 _aUNION EUROPEA
773	0		_9163476 _oWTJ/2020/1 _tWorld Tax Journal _w(IEF)62814 _gv. 12, n. 1, 2020
942			_cRE