Translation of "Traitement fiscal des bénéfices " (French → English) :

tax treatment of parent and subsidiary companies

tax treatment of mergers and divisions

fair tax treatment [ fair tax system ]

tax treatment of capital gains

Canadian R&D Tax Treatment: An International Comparison

taxable income | income liable to tax | assessable income | taxable profits

income tax expense | income taxes | provision for income taxes | tax expense

liability method | accrual method | accrual method of tax allocation | asset and liability method | asset and liability method of accounting for income taxes | asset-liability method | liability method of tax allocation

Finally, the Commission's decision that Belgium's "excess profit" ruling system was contrary to EU state aid rules was also based on derogations from the "arm's length principle". Profit allocation methods, which do not reflect economic reality: The Commission decided in August 2016 that Apple received illegal tax benefits in Ireland because the tax rulings endorsed a method to internally allocate profits within two Irish Apple group companies, which did not have any factual or economic justification. Inconsistent application of national law, giving rise to a discretionary double non-taxation: Today's investigation into Luxembourg's tax treatment of GDF Suez looks i ...[+++]nto an alleged inconsistent application of national tax law endorsed in the tax rulings, leading to double non-taxation.

The tax treatment appears to give rise to double non-taxation for both lenders and borrowers on profits arising in Luxembourg.

Furthermore, differences across Member States in the definition of debt and equity and their respective tax treatment, including in relation to regulatory capital instruments, may hamper a level-playing field, fragment markets and create opportunities for profit-shifting.

For the purpose of avoiding situations of double non-taxation deriving from mismatches in the tax treatment of profit distributions between Member States, the Member State of the parent company and the Member State of its permanent establishment should not allow those companies to benefit from the tax exemption applied to received distributed profits, to the extent that such profits are deductible by the subsidiary of the parent company.