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EN
This article deals with international tax law applicable to holding companies and related issues. Particularly in a time of globalization, international holding companies have been shaping the European economy. Tax optimization is an inextricable element of the tax strategies followed by holding companies, which may take various forms – from an aggressive one to tax optimization which is permitted by law. Tax optimization makes use of numerous legal and financial instruments. The legal consequences of application of such instruments are of immense significance not only for holding companies but for the interest of state budgets as well.
EN
The aim of this paper is to present CCCTB system in the aspect of a necessity for a complex reform of tax law in order to enhance competitiveness of Polish enterprises. The concept proves to be a chance for a new standard in the Polish tax system and the improvement of the income tax. The author will also conduct the analysis of possible standardizing solutions within the tax system of the European Union, taking into account the importance and attractiveness of this solution for Polish enterprises
EN
Small and medium-sized enterprises (SMEs) are facing internal markets with higher taxation and transfer price compliance costs as well as cross-border loss compensation problems. With respect to the taxation (transfer pricing) compliance costs that are borne by SMEs, the possible solutions for decreasing those costs were suggested to be safe harbours and common (consolidated) corporate tax bases. This paper includes an evaluation of the suggested approaches and their impacts on the SMEs’ economic performance. In addition, this evaluation accounts for the selected economic variables that are classified by industry and firm size, assuming decreased compliance costs of taxation and the fulfilment of the long-term goals of the EU2020 agenda, such as smart and inclusive growth in the EU. Based on the results, it can be concluded that safe harbours and the CCCTB system are able to improve SMEs’ performance. The most important economic variables supporting the increase in business performance are current assets, value added, enterprise value and, finally, operating revenues. In researched countries, the highest impact on the business performance would result from the created added value.
EN
This paper evaluates the impact of the European Commission’s Proposal for a Council directive on the Common Consolidated Corporate Tax Base (CCCTB) (COM (2011) 121/4). We analyse the impact of the apportionment formula to be applied to the CCCTB on the revenues of the Slovak state budget. The sample of our analysis is composed of eleven transnational corporations operating in the Slovak Republic and other EU member states. The results indicate a decrease in tax revenues under the proposed CCCTB system in comparison to the current national tax legislation. By contrast, according to the data available, the likelihood that Slovakia will benefit from the CCCTB system by collecting more taxes seems to be low.
EN
The European Commission re-launched its proposal on the Common Consolidated Corporate Tax Base (CCCTB) in Europe in October 2016. The CCCTB aims to help ensure a fair and efficient corporate tax system in the European Union as a tool to fight tax evasion and tax fraud. Moreover, the CCCTB could be intended to be used as a new resource for the EU budget, as the EU budget requires reassessment after Brexit. Although the outcome of the Brexit process was uncertain for a long time, the UK left the EU on 31 January 2020. The objective of this paper is to research the impact of the introduction of the CCCTB on the EU’s economic environment in the post-Brexit period. The research reveals that the overall tax base under the CCCTB in the post-Brexit period would decline by 5.34% in comparison with the current tax base. Through a dynamic approach, we find that the CCCTB could increase the tax base by between 3.33% and 22.42%, depending on the behavioural effects induced by the implementation of the proposal.
EN
European Commission re-launches the common consolidated corporate tax base (CCCTB) in Europe within the efforts to fight with tax evasion and tax fraud via two step procedure. Firstly, only a common corporate tax base (CCTB) would be implemented with the possibility of cross-border loss offsetting CCCTB. Common consolidated corporate tax base should be introduced only in the second step. The aim of the paper is to research the impact of both implementation steps on the amount of the tax bases allocated in the Slovak Republic. The results show, that the first implementation step would results into the decrease of allocated tax bases by 0.27% in the Slovak Republic. The second implementation step would result in to the increase of the tax bases allocated in the Slovak Republic by 3.02%.
EN
One of the main objectives to be accomplished by the European Union law is to eliminate barriers to the functioning of domestic market and in particular improve the competitiveness of enterprises. After several years of efforts, the European Commission approved a proposal for the directive on a Common Consolidated Corporate Tax Base which is to remove obstacles to the functioning of internal market and increase tax harmonization. The article is aimed at presenting the essence of CCCTB in the theory of corporate finance and its importance for enterprises, based on the survey of Polish and EU companies. The paper addresses issues relating to tax in corporate finance. Canons of taxation will be discussed and special emphasis will be placed on principles behind formulating fiscal law provisions (including the EU law). Furthermore, the article presents the results of surveys into the importance of taxation cannons for Polish and EU companies.
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