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The Taxation of Corporate Groups under Consolidation
An International Comparison

$115.00 ( ) USD

Part of Cambridge Tax Law Series

  • Date Published: December 2012
  • availability: This ISBN is for an eBook version which is distributed on our behalf by a third party.
  • format: Adobe eBook Reader
  • isbn: 9781139604390

$ 115.00 USD ( )
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About the Authors
  • The rise of corporate groups in the last century dictates a shift in the income tax law: instead of treating each company as a separate taxpayer, the tax consolidation regime is increasingly common. Antony Ting presents the first comprehensive comparative study of eight consolidation regimes in Australia, France, Italy, Japan, the Netherlands, New Zealand, Spain and the USA. In the study, he critically analyses and compares alternative policy options with respect to ten key structural elements. The study improves understanding of the design and implementation of consolidation regimes and sets the stage for the search for a model. It provides valuable information with respect to the best practices, as well as the pitfalls, in the design of a consolidation regime. The book is essential to countries contemplating the introduction of a new consolidation regime and offers important insights into the management of such a complex structure through careful policy-orientated choices.

    • Comparative study of consolidation regimes provides essential information to countries contemplating the introduction or fine-tuning of a consolidation regime
    • Analyses alternative policy options with respect to ten key structural elements, thereby improving the understanding of the design and implementation of consolidation regimes
    • Provides important insights into how the application of the enterprise doctrine to the taxation of corporate groups can affect the complexity of a tax system and how the level of complexity can be managed to a large extent through the choices of policy options
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    Product details

    • Date Published: December 2012
    • format: Adobe eBook Reader
    • isbn: 9781139604390
    • contains: 31 b/w illus. 11 tables
    • availability: This ISBN is for an eBook version which is distributed on our behalf by a third party.
  • Table of Contents

    Part I. The Enterprise Doctrine – Theory and Practice:
    1. The rise of corporate groups: a challenge to the tax law
    2. Application of the enterprise doctrine to group taxation: theory
    3. Application of the enterprise doctrine to group taxation: practice
    Part II. Comparative Analysis of Key Structural Elements of Consolidation Regimes:
    4. Policy objectives and structural elements of consolidation
    5. Definition of a group
    6. Treatment of losses
    7. Treatment of assets
    8. Treatment of intra-group shareholdings
    9. Interactions between consolidation and other parts of the income tax system
    10. A model consolidation regime?

  • Author

    Antony Ting, University of Sydney
    Antony Ting is a senior lecturer at the University of Sydney Business School. He was previously a tax partner in a major international accountancy firm, advising multinational companies on corporate tax as well as international tax issues.

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