Jurisdiction to tax corporate income pursuant to the presumptive benefit principle : a critical analysis of structural paradigms underlying corporate income taxation and proposals for reform / Eva EscribanoMaterial type: BookCall no.: K4544 .E83 2019Series: Series on international taxation: no. 70.Publication: Alphen aan den Rijn, the Netherlands : Kluwer Law International B.V., c2019Description: xxvii, 299 p. : ill.Notes: Originally presented as the author's thesis (doctoral)--Universidad Carlos III de Madrid, 2018.ISBN: 9789403506401; 9403506407.Subject(s): Corporations -- Taxation -- Law and legislation
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Originally presented as the author's thesis (doctoral)--Universidad Carlos III de Madrid, 2018.
Includes other bibliographical references (pages 277-290).
The Profit Shifting Phenomenon Unrevealed and the Presumptive Benefit Principle as an Equitable Tax Policy Guideline to Counteract It -- Three Fundamental Paradigms Underlying Corporate Income Taxation Are Inconsistent with the Presumptive Benefit Principle and Tend to Inherently Trigger Profit Shifting Risks -- Proposals for a CIT Reform in the Light of the Presumptive Benefit Principle.
Jurisdiction to Tax Corporate Income Pursuant to the Presumptive Benefit Principle' intends to demonstrate that the profit shifting phenomenon (e.g., the ability of companies to book their profits in jurisdictions other than those that host their economic activities) is real, severe, undesirable, and above all, the natural consequence of both the preservation of three fundamental paradigms that have historically underlain corporate income taxes and their precise legal configuration. In view of this, the book submits a number of proposals in relation to the aforementioned paradigms and in the light of the suggested "presumptive benefit principle" so as to counteract profit shifting risks and thus attain a more equitable allocation of taxing rights among States.
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