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Title: The international aspects of the European common consolidated corporate tax base (CCCTB) and their interaction with third countries
Authors: Ali, Eid Ashry Gaber
Advisors: Olowofoyeku, A
Cerioni, L
Keywords: Direct taxtion;Corporate tax harmonisation;Taxing maltinationals;Formulary apportionment;Egypt's corporate tax system
Issue Date: 2013
Abstract: The thesis examines the international taxation rules of the Common Consolidated Corporate Tax Base (CCCTB) and their interaction with third-country corporate tax practice. The aim is to assess the effectiveness of the CCCTB vis-à-vis third countries, with Egypt as a practical example. The CCCTB has the potential to reduce corporate tax obstacles faced by businesses in the EU in having to comply with up to twenty seven different domestic systems for determining their taxable profits. However, the international taxation rules of the CCCTB system are likely to have an impact on the corporate tax practice in third countries, and may conflict with existing bilateral tax treaties concluded between CCCTB-Member States and third countries. The discussion presents a detailed analysis of the CCCTB’s unilateral framework for the avoidance of double taxation and for the protection of the common consolidated tax base. It reveals that, by means of ordinary credit and exemption methods provided in the CCCTB Directive, international double taxation will be eliminated in relation to third countries. Furthermore, the CCCTB’s anti-abuse rules are effective in protecting the common tax base and in eliminating non-double taxation. Nevertheless, the unilateral measures are in conflict with a number of important provisions of bilateral tax treaties, based on the OECD Model, concluded between the potential CCCTB-Member States and third countries. Egypt exemplifies this – but the problem is generic. These conflicts between the CCCTB and OECD Model bilateral treaties are detrimental to the effective functioning of the CCCTB system vis-à-vis third countries, and need to be redressed. This thesis suggests a simple and practical solution - replacement of the bilateral tax treaties between CCCTB-Member States and third countries with a multilateral tax treaty to be concluded between every third country and all CCCTB-Member States.
Description: This thesis was submitted for the degree of Doctor of Philosophy and awarded by Brunel University.
Appears in Collections:Law
Dept of Politics, History and Law Theses

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