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Thin Capitalization Rules in the Context of the CCCTB

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  • Rita de la Feria

    ()
    (Oxford University Centre for Business Taxation)

  • Ana Paula Dourado

    (Faculty of Law, University of Lisbon)

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    Abstract

    In the context of the proposed European CCCTB there is clearly a perceived need for the introduction of a common thin capitalization rule. This rule would be aimed at dealing with inbound investment emerging from both third countries, and from Member States opting out of the CCCTB. The principal aim of this paper is to establish whether such a need does indeed exist, and if so, which considerations should guide the design of a thin capitalization rule for the CCCTB. The paper starts by providing a broad summary of the varying approaches of Member States to thin capitalization. It then makes the case for the introduction of a thin capitalization rule in the context of the CCCTB, from both an economic and a legal perspective, and sets out the general principles which should guide the design of such a rule.

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    Bibliographic Info

    Paper provided by Oxford University Centre for Business Taxation in its series Working Papers with number 0804.

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    Date of creation: 2008
    Date of revision:
    Handle: RePEc:btx:wpaper:0804

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    Keywords: Thin capitalization; CCCTB;

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    Cited by:
    1. Schindler, Dirk & Schjelderup, Guttorm, 2012. "Debt shifting and ownership structure," European Economic Review, Elsevier, vol. 56(4), pages 635-647.
    2. Thiess Buettner & Michael Overesch & Georg Wamser, 2014. "Anti Profit-Shifting Rules and Foreign Direct Investment," CESifo Working Paper Series 4710, CESifo Group Munich.
    3. Andreas Haufler & Marco Runkel, 2008. "Firms' financial choices and thin capitalization rules under corporate tax competition," Working Papers 0815, Oxford University Centre for Business Taxation.
    4. Georg Wamser, 2008. "The Impact of Thin-Capitalization Rules on External Debt Usage – A Propensity Score Matching Approach," Ifo Working Paper Series Ifo Working Paper No. 62, Ifo Institute for Economic Research at the University of Munich.
    5. Dreßler, Daniel & Scheuering, Uwe, 2012. "Empirical evaluation of interest barrier effects," ZEW Discussion Papers 12-046, ZEW - Zentrum für Europäische Wirtschaftsforschung / Center for European Economic Research.
    6. Schindler, Dirk & Schjelderup, Guttorm, 2008. "Multinationals, Minority Ownership and Tax-Efficient Financing Structures," Discussion Papers 2008/19, Department of Business and Management Science, Norwegian School of Economics.
    7. Buettner, Thiess & Overesch, Michael & Schreiber, Ulrich & Wamser, Georg, 2012. "The impact of thin-capitalization rules on the capital structure of multinational firms," Journal of Public Economics, Elsevier, vol. 96(11), pages 930-938.

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