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Thin Capitalization Rules in the Context of the CCCTB


  • Rita de la Feria

    () (Oxford University Centre for Business Taxation)

  • Ana Paula Dourado

    (Faculty of Law, University of Lisbon)


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.

Suggested Citation

  • Rita de la Feria & Ana Paula Dourado, 2008. "Thin Capitalization Rules in the Context of the CCCTB," Working Papers 0804, Oxford University Centre for Business Taxation.
  • Handle: RePEc:btx:wpaper:0804

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    Cited by:

    1. Mardan, Mohammed, 2017. "Why countries differ in thin capitalization rules: The role of financial development," European Economic Review, Elsevier, vol. 91(C), pages 1-14.
    2. Ruf Martin & Schindler Dirk, 2015. "Debt Shifting and Thin-Capitalization Rules – German Experience and Alternative Approaches," Nordic Tax Journal, De Gruyter Open, vol. 2015(1), pages 17-33, September.
    3. Andreas Haufler & Marco Runkel, 2008. "Firms’ Financial Choices and Thin Capitalization Rules under Corporate Tax Competition," CESifo Working Paper Series 2429, CESifo Group Munich.
    4. Haufler, Andreas & Runkel, Marco, 2012. "Firms' financial choices and thin capitalization rules under corporate tax competition," European Economic Review, Elsevier, vol. 56(6), pages 1087-1103.
    5. Thiess Büttner & Michael Overesch & Georg Wamser, 2014. "Anti Profit-Shifting Rules and Foreign Direct Investment," CESifo Working Paper Series 4710, CESifo Group Munich.
    6. Schindler, Dirk & Schjelderup, Guttorm, 2012. "Debt shifting and ownership structure," European Economic Review, Elsevier, vol. 56(4), pages 635-647.
    7. Georg Wamser, 2014. "The Impact of Thin-Capitalization Rules on External Debt Usage – A Propensity Score Matching Approach," Oxford Bulletin of Economics and Statistics, Department of Economics, University of Oxford, vol. 76(5), pages 764-781, October.
    8. repec:ces:ifodic:v:12:y:2015:i:4:p:19151968 is not listed on IDEAS
    9. 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.
    10. 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.
    11. Schindler, Dirk & Schjelderup, Guttorm, 2008. "Multinationals, Minority Ownership and Tax-Efficient Financing Structures," Discussion Papers 2008/19, Norwegian School of Economics, Department of Business and Management Science.
    12. Kalamov, Zarko Y., 2015. "Safe Haven vs. Earnings Stripping Rules: a Prisoner Dilemma?," EconStor Preprints 110895, ZBW - German National Library of Economics.
    13. Valeria Merlo & Georg Wamser, 2015. "Debt Shifting and Thin-capitalization Rules," ifo DICE Report, ifo Institute - Leibniz Institute for Economic Research at the University of Munich, vol. 12(4), pages 27-31, 01.

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    Thin capitalization; CCCTB;

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