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Harmonisation des Impôts sur les Sociétés dans la Communauté
The Ruding Report and Council Conclusions
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achieved action activities adopted agreed apply approach arise benefits capital Commission Community competition concerning Conclusions condition Congress convention corporate income tax corporate tax costs Council countries cross-border deduction Directive discussed distortions distributions dividends domestic double taxation economic effect elimination enterprises entities Etats Membres European example exemption existing factors fiscal foreign France Germany granted groups harmonization holding implementation important incentives included interest internal market introduced investment issues Italy legislation limited losses measures Member method necessary Netherlands operating parent company parent-subsidiary participation period permanent establishment Phase practice principle problems profits proposed question received recommended relief requires resident result Ruding Ruding Report rules scope société subsidiary tax base tax credit tax harmonization tax rate tax systems tax treaties tion transfer treatment United Kingdom withholding tax