The Principle of Territoriality and its Implementation in the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)

Authors

• Michael Lang, Vienna University of Economics and Business AdministrationFollow

Abstract

This paper will focus on some provisions of the proposal that are relevant for companies that are tax residents outside the European Union or for commercial activities carried outside the EU, and for EU resident companies that operate in third countries. This paper will primarily discuss the territoriality principle, on which the CCCTB concept is based, and its legal technical structure. However, this paper will not discuss other provisions of the proposal, even if those should specifically address third-country scenarios, such as those concerning deductibility of donations, the transfer of assets, or deductibility of interest.

Recommended Citation

Lang, Michael (2013) "The Principle of Territoriality and its Implementation in the Proposal for a Council Directive on a Common Consolidated Corporate Tax Base (CCCTB)," Florida Tax Review: Vol. 13: No. 1, Article 7.
Available at: https://scholarship.law.ufl.edu/ftr/vol13/iss1/7